Lawsuit Filed Against Diddy

Case 1:24-cv-01457-JPO Document 27 Filed 03/27/24 Page 1 of 98
UNITED STATES FEDERAL COURT

SOUTHERN DISTRICT OF NEW YORK
RODNEY JONES,
Plaintiff, Case Number: 24-1457
V. Second Amended Complaint

Civil Action
SEAN COMBS,
JUSTIN DIOR COMBS Jury Demand
CUBA GOODING JR.,
LUCIAN CHARLES GRAINGE,
KRISTINA KHORRAM,
LOVE RECORDS,
MOTOWN RECORDS,
UNIVERSAL MUSIC GROUP,
COMBS GLOBAL ENTERPRISES,
JOHN and JANE DOES 1-10 and
ABC CORPORATIONS. 1-10
Defendants.
TRIGGER WARNING:
TIDS DOCUMENT CONTAINS HIGHLY GRAPHIC INFORMATION OF A
SEXUAL NATURE,INCLUDING SEXUAL ASSAULT. ADDITIONALLY,
THERE ARE GRAPHIC IMAGES OF THE AFTERMATH OF A SHOOTING,
REDACTED IMAGES OF SEXUAL INTERCOURSE,REDACTED IMAGES OF
MINORS,SEX WORKERS,AND PROSTITUTES, DETAILS OF SEX
TRAFFICKING,AND THE ILLEGAL DISTRIBUTION OF GUNS, AND DRUGS
Plaintiff Rodney "Lil Rod" Jones ("Mr. Jones") hereby alleges, as and for his Complaint
against Defendant Sean Combs ("Mr. Combs"), Defendant Justin Dior Combs ("J. Combs"),
Defendant Lucian Charles Grainge ("Mr. Grainge"), Defendant Cuba Gooding Jr. ("Mr. Gooding
Jr."), Defendant Kristina Khorram ("Ms. Khorram"), Defendant Love Records ("LR"), Defendant
Motown Records ("MR"), Defendant Universal Music Group ("UMG"), Defendant Combs Global
Enterprises ("CGE"), John and Jane Does 1-10, ABC Corporations 1-10, as follows:
JURISDICTION AND VENUE

1. This Court has personal jurisdiction over the Defendants under and consistent with the
Constitutional requirements of Due Process in that the Defendants, acting directly or through
his agents or apparent agents, committed one or more of the following:
a. The transaction of any business within the state;
b. The making of any contract within the state;
c. The commission of a tortious act within this District; and
d. The ownership, use, or possession of any real estate in this state.
2. From September 2022 to the date of this filing, Defendants have consistently and purposefully
availed themselves of the privilege of conducting activities within New York, thus invoking
the benefits and protections of New York law. In return for these benefits and protections,
Defendants must submit to the burdens of litigation in New York.
3. This litigation arises from or relates to the tortious activities the defendants visited upon
Plaintiff Jones in New York, California, Florida, Saint Barthelemy, and the United States
Virgin Islands. This tortious conduct violated United States Federal Rico Laws and the United
States Victims (“USVI”) of the Trafficking and Violence Protection Act of 2000 (“TVPA”).
4. Requiring Defendants to litigate these claims in this District does not offend traditional
notions of fair play and substantial justice. Plaintiffs’ claims arise from some conduct
occurring by Defendants in New York. Specifically, the trafficking of Plaintiff across State
lines between California, Florida, New York, and the USVI, and the trafficking of Plaintiff
internationally to Saint-Barthélemy.
PARTIES
5. Plaintiff Rodney Jones is an American artist and music producer. Mr. Jones is domiciled in
the state of New York.
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Defendant Sean Combs

6. Defendant Sean Combs is a rapper and record executive popularly known by his stage names
Puff Daddy, Puffy, P. Diddy, Diddy, Brother Love or Love. Mr. Combs became famous in the
early 1990s with his record label Bad Boy Records. He rose to prominence in the music and
entertainment industry over the decades and is regularly referred to as a hip-hop mogul. Mr.
Combs is domiciled at 200 South Mapleton Dr., Beverly Hills, California 90024.
Defendant Justin Dior Combs

7. Defendant Justin Dior Combs is the son of Mr. Combs and Misa Hylton. J. Combs was born
on December 30, 1993. J. Combs is a producer and actor. He has appeared on TV series like
Catfish: The TV Show, Wild' N Out, and Hip-Hop Squares. Defendant Justin Dior Combs is
domiciled at 1550 N El Centro Ave, Los Angeles, CA 90028.
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Lucian Charles Grainge

8. Defendant Lucian Charles Grainge is the CEO of Defendant Universal Music Group. Upon
information and belief, Defendant Lucian Charles Grainge is domiciled at 53551 Ross Ave
Unit 34A, La Quinta, CA 92253, and 668 Chautauqua Blvd, Pacific Palisades, CA 90272.
Defendant Lucian Charles Grainge, in his capacity as CEO of UMG, authorized Motown
Records and Universal Music Group to enter into a general business partnership agreement
and to provide financial resources to their general business partners, Defendants Sean Combs
and Love Records, Inc.
Cuba Gooding, Jr.

9. Defendant Cuba Gooding, Jr. was a relevant actor who has fallen from grace due to several
sexual assault lawsuits and a recent guilty plea for sexual assault. Upon information and
belief, Defendant Gooding, Jr. is domiciled at 60 Collister Street, Apt. #2B, New York, NY
10013.
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Kristina Khorram, Chief of Staff to Sean "Diddy" Combs

10. Defendant Kristina Khorram is the Chief of Staff to Sean “Diddy” Combs, Combs Global
Enterprises. Upon information and belief, she is domiciled at 10445 Wilshire Blvd Apt 501,
Los Angeles, CA 90024. Defendant Khorram manages the day-to-day operation of the
Combs RICO and TVPA Enterprises.
11. Defendant Motown Records is a record label with a principal place of business located at 1750
Vine St, Los Angeles, CA. According to a Declaration by former Motown Chairwoman and
CEO Ethiopia Habtemariam, Motown Records, with the consent of Defendant UMG, and
presumably, Ms. Habtemariams direct supervisor, Defendant Lucian Grainge, entered a
general partnership, as that term is defined by the laws of the State of New York, with
Defendants Love Records, Inc. and Sean Combs.
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12. Defendant Universal Music Group is a record label with a principal place of business located
at 2220 Colorado Avenue in Santa Monica, California. Lucian Grainge is the Chairman &
CEO of Universal Music Group. Defendant Lucian Charles Grainge, as CEO of UMG,
authorized Universal Music Group to enter a general business partnership with Love Records,
Inc. and Sean Combs. Additionally, according to former Motown Records Chairwoman, Ms.
Habtemariam, they provided funding and/or reimbursements for expenses associated with the
recording cost of the Love Album. The Love Album was released on September 23, 2023.
13. Defendant Love Records is a record label with a principal place of business located at 6255
Sunset Boulevard Suite 713. Los Angeles, CA, United States 90028. Defendant Combs
founded Defendant Love Records. According to their website, Defendant Motown Records
helped Sean Combs establish Love Records and had a distribution deal for the Love Album.
Combs Global
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20. Mr. Jones agreed, and his life has been detrimentally impacted ever since.
21. During the relevant period, Defendants John and Jane Does 1-10 are currently unknown
individuals and/or employees who aided and/or abetted in the commission of conduct
complained of herein and/or who either acted within the scope of their employment,
Defendants ratified, embraced, and added to this conduct. As parties engage in discovery,
Plaintiff retains the right to amend the Complaint to add these individual employees by name.
22. During the relevant period, Defendants ABC Corps. 1-10 are currently unknown entities who
employed Plaintiff or aided and/or abetted in the commission of conduct complained of
herein. As the parties engage in discovery, Plaintiff retains the right to amend the Complaint
to add these entities or individuals by name.
SUMMARY OF EVENTS
23. From September 2022 to September 2023, Mr. Jones produced nine songs on Mr. Combs'
Love album.
24. From September 2022 to September 2023, Mr. Jones lived with Mr. Combs for months,
spending holidays, birthdays and missing major family events.
25. Mr. Jones resided at Mr. Combs's residences in Los Angeles, California, and Miami, Florida.
He also spent several weeks on a yacht rented by Mr. Combs in the US Virgin Islands and
Saint-Barthélemy. As detailed below, Mr. Jones made several trips with Mr. Combs to New
York City throughout his time living with him.
26. Throughout his time with Mr. Combs, Mr. Jones witnessed, experienced, and endured many
things that went far beyond his role as a Producer on the Love album.
27. The claims raised in this complaint have been corroborated through witness statements,
video/audio recordings, personal experiences, and images Mr. Jones possesses.
28. Mr. Combs required Mr. Jones to record him constantly. On several occasions, Mr. Combs
took Mr. Jones's cell phone and began recording himself. As a result, Mr. Jones has secured
HUNDREDS of hours of footage and audio recordings of Mr. Combs, his staff, and his guests
engaging in serious illegal activity.
29. Mr. Jones has personally witnessed and secured irrefutable evidence of:
a. The acquisition, use, and distribution of ecstasy, cocaine, GHB, ketamine, marijuana,
and mushrooms,
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b. The displaying and distribution of unregistered illegal firearms,

c. Mr. Combs providing laced alcoholic beverages to minors (LA home July 2023) and
sex workers at his homes in California, the U. S. Virgin Islands1, Florida, and Saint-
Barthélemy,
d. Mr. Combs Chief of Staff, Kristina Khorram (“KK”) instructs her staff to retrieve
drugs so she can provide them to Mr. Combs for his consumption,
e. Christian Combs drugging and sexually assaulting a woman2,
f. Mr. Combs detailing how he planned to leverage his relationship with Bishop T.D.
Jakes, to soften the impact on his public image of Cassie Ventura’s lawsuit,
g. Yung Miami’s cousin and or assistant sexually assaulting Mr. Jones,
h. Actor Cuba Gooding Jr. sexually harassing and assaulting Mr. Jones,
i. Rapper3 (REDACTED) on Mr. Combs yacht consorting with underaged girls, sex
workers, and
j. R&B Singer4 (REDACTED) in Mr. Combs Los Angeles home consorting with
underaged girls and sex workers.
CHALICE RECORDING STUDIOS SHOOTING

30. On or about September 12, 2022, Mr. Combs held a writers and producers camp at Chalice
Recording Studio at 845 Highland Ave, Los Angeles, CA 90038.
31. Mr. Combs, his son Justin Combs, and Justin's friend G were present at this camp.
32. Based on information and belief, Mr. G is a 30-year-old tall African American male.
33. Based on information and belief, in addition to these individuals, other musicians were present
at the camp. This writer has spoken to several musicians who attended the camp.
34. One evening during this camp, Mr. Combs, J. Combs, and G were in a heated conversation.
35. That conversation was moved out of the studio and into a restroom adjacent to where Mr.
Jones was sitting.
1
This writer spoke with several employees of the yacht rented by Mr. Combs in the U.S. Virgin Islands and Saint-
Barthélemy who personally witnessed Defendant Khorram instruct her staff, Brendan Paul, Frankie Santella, and Moy
Baun spike bottles of champagne with ecstasy. Upon information and belief, this occurred the day of the December
31, 2022 New Year’s Eve party.
2
A complaint is forthcoming.
3
He is a Philadelphia Rapper who dated Nicki Minaj.
4
He is a Grammy Award winning R&B singer who had trouble with law enforcement after assaulting a Bajan
Billionaire.
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36. Mr. Jones was approximately 2 feet away from the bathroom when gunshots rang out. Mr.
Jones recalls hearing multiple gunshots.
37. Mr. Jones immediately went into a state of shock and feared that he would be shot next. Mr.
Jones genuinely believed that he would be shot through the door due to how close he was.
38. After the shooting ended, a crowd gathered around the restroom.
39. Upon information and belief, when the door finally opened, Mr. Combs and J. Combs exited.
40. G was lying on the restroom floor in a fetal position, holding his stomach and bleeding out of
his torso and leg/hip area.
41. Everyone stood around looking upon G. Frustrated by the lack of aid to G, Mr. Jones dropped
everything, ran to G, and immediately began placing pressure on G's gunshot wound to his
torso.
42. As he was applying pressure to his torso, Mr. Jones realized that G was gushing blood from
another area near his leg/hip.
43. He decided to lift G and placed him to sit on the toilet. Mr. Jones asked the crowd to call the
ambulance.
44. Mr. Jones lifted G and brought him to the ambulance at the front of the studio. At this time,
Mr. Combs and Justin disappeared to another part of the studio.
45. Mr. Combs gave strict instructions to inform the police that he had nothing to do with the
shooting. He also forced Mr. Jones to lie to the police by telling them that G was shot standing
outside the studio by a drive-by assailant.
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46. Mr. Jones has several corroborating witnesses who spoke with this writer anonymously
because they feared retaliation from Mr. Combs. They have agreed to speak publicly when
subpoenaed.
47. Mr. Jones has the clothing he wore that day and believes it may still have G's blood stains and
DNA.
48. The following are screenshots of the aftermath of the restroom where G was shot by either
Mr. Combs or J. Combs:
Aftermath of the Shooting of G

49. Upon information and belief, it is clear that G was NOT shot outside of the studio, as Mr.
Combs instructed his team to report to law enforcement.
50. Upon information and belief, Mr. Combs and Defendant’s LR, MR, UMG, and CRS provided
private security for the writers’ camp at Chalice.
51. The Security was porous and lackluster at best.
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52. The fact that either Mr. Combs and J. Combs were allowed to enter CRS with guns, and those
guns were not confiscated by security is a clear breach of duty by Mr. Combs, Defendant’s
LR, MR, and UMG to protect Mr. Jones and the other attendees of this writers’ camp.
53. As a result of this shooting, Mr. Jones is severely traumatized. Mr. Jones now suffers from
PTSD, severe anxiety, depression, and insomnia.
54. The following is an image of Mr. Combs a couple of hours before G is shot in the restroom of
Chalice:
This photo of Mr. Combs was taken at Chalice Recording Studios outside of Studio G
hours before G was shot.
CHALICE RECORDING STUDIOS, AND DEFENDANTS SEAN COMBS AND JUSTIN

COMBS REPRESENTATIVE SHAWN HOLLEY
PROVIDE CONFLICTING AND INTELLECTUALLY DISHONEST ACCOUNTS
CONCERNING THE SHOOTING
55. On or about, February 28, 2024, Chalice sent an Instagram message which alleges that G was
shot a “half a block away from Chalice.”
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65. Mr. Combs and J. Combs were located in Studio G across the parking lot from the building
where G was shot (near Studio A). Mr. Combs and J. Combs hid out in Recording Studio G
while the police “investigated,” and were the first to depart after the officers left7.
Mr. Combs Published the Love Records Chalice Recording Studios

Assignment List. Mr. Combs Stayed in Studio G
Throughout The Duration of the Writers Camp
66. Upon information and belief, after being shot in the torso and hip/leg, G was physically
incapable of walking; therefore, the notion that he was shot several blocks away (Shawn
Holley), half a block away (CRS), or as he stepped outside of the studio is implausible.
67. If G could do as much walking as Shawn Holley and CRS claim, then Mr. Jones would not
have been required to physically pick him up off the restroom floor and walk him through the
maze that is CRS for him to receive care from the ambulance.
7
This FACT will be made crystal clear in discovery.
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68. As of the date of this filing, neither the Los Angeles Police Department nor the Los Angeles
Fire Department has released any official reports surrounding this shooting. There has been
no body camera footage or 911 call recording. What is even more disturbing is that there has
been no citing of G.
a. The LAPD has only released a vaguely written "News Release" dated September 12,
2022.
69. The unfortunate shooting of G, the unexplained disappearance of G, the lack of disclosures
by the LAPD and LAFD, and the incoherent nature of Shawn Holley and Chalice Recording
Studios' account of the shooting raises more questions than answers point to foul play, and an
apparent massive coverup.
THE DEAFENING SILENCE FROM THE ATTENDEES OF THE CRS SHOOTING

STEMS FROM UNDERSTANDABLE FEAR THAT THE ATTENDEES WOULD BE
SUED BY MR. COMBS FOR VIOLATING A
NON-DISCLOSURE AGREEMENT
70. Upon information and belief, a few days before the September 12, 2022, shooting inside of
Chalice Recording Studio, Mr. Combs required all attendees of the CRS shooting to sign a
Non-disclosure Agreement.
71. Mr. Jones did not sign the agreement.
72. A copy of the non-disclosure agreement8 that a witness who has asked to remain anonymous
provided this writer is attached. (Attachment A).
MR. JONES WAS SEXUALLY HARASSED, AND ASSAULTED BY MR. COMBS

73. Throughout his time living with Mr. Combs, Mr. Jones was the victim of constant unsolicited
and unauthorized groping and touching of his anus by Mr. Combs.
74. These events occurred in LA, NY, FL, Saint-Barthélemy, and the United States Virgin Islands.
75. In addition to the unsolicited and unauthorized touching, Mr. Jones was forced by Mr. Combs
to work in Mr. Combs' bathroom as Mr. Combs walked around naked and showered in a clear
glass enclosure.
8
Unfortunately for the attendees of the writers’ camp, they are unaware that NDA’s are non-binding when it comes
to reporting criminal activity such as a shooting, sex trafficking, and the distribution and use of illegal drugs and
guns.
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76. As a heterosexual Christian man, Mr. Jones was uncomfortable with Mr. Combs' advances
and expressed his discomfort to Mr. Combs' Chief of Staff, Defendant Kristina Khorram.
77. KK responded to Mr. Jones complaint with, "you know, Sean will be Sean.”
78. KK also attempted to downplay Mr. Combs groping of Mr. Jones's anus and genitals as
friendly horseplay, stating that those acts were Mr. Combs's way of "showing that he likes you
[Mr. Jones].”
79. Despite these assurances, on several occasions, when Mr. Combs began to undress and walk
around his house naked, KK would say, "Okay, I am leaving now," and she would disappear.
KK's hypocrisy is breathtaking at best or enabling at worst.
80. Mr. Jones believes that KK aided and abetted Mr. Combs' sexual assault and was working
with Mr. Combs to groom him into accepting a homosexual relationship.
81. Through these sexually deviant acts, one would say Mr. Combs has a pattern and practice of
engaging in such nefarious activity. This ongoing conduct shows that Mr. Combs cannot be
rehabilitated.
MR. COMBS ATTEMPTED TO GROOM MR. JONES INTO ENGAGING IN GAY SEX
82. Mr. Combs knew Mr. Jones looked up to and idolized music Producer Steven Aaron Jordan
("Stevie J").
83. Based on information and belief, Stevie J is an American DJ, record producer, and television
personality.
84. Based on information and belief, Stevie J was part of the Bad Boy Records production team,
the Hitmen.
85. Upon information and belief, in 1997, Stevie J won a Grammy Award for his work on Puff
Daddy's debut album.
86. Upon information and belief, throughout the late 1990s, Stevie J produced for several artists,
including Mariah Carey, Tevin Campbell, The Notorious B.I.G., 112, Jodeci, Faith Evans,
Jay-Z, and Eve.
87. Based on information and belief, Stevie J was one of the producers of the Love Album.
88. According to Mr. Jones, Mr. Combs used access to Stevie J and his knowledge of Mr. Jones'
admiration of Stevie J to groom and entice Mr. Jones to engage in homosexual acts.
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89. Mr. Combs went so far as to share a video of who he claims was Stevie J9 anally penetrating
a Caucasian male without a condom. Mr. Jones believes that Mr. Combs showed him this and
attributed it to his idol Stevie J. to ease Mr. Jones’ anxiety concerning homosexuality.
According to Mr. Jones, Mr. Combs said, “this is a normal practice in the music industry, look
even Stevie J10 is doing it.”
90. According to Mr. Jones, Mr. Combs informed Mr. Jones that he had engaged in sexual
intercourse with rapper11 (REDACTED), R&B singer12 (REDACTED), and Stevie J.
91. According to Mr. Jones, Mr. Combs promised to make sure that Mr. Jones wins producer of
the year at the Grammys if he engaged in homosexual acts.
THANKSGIVING 2022, MR. JONES IS SEXUALLY ASSAULTED BY

YUNG MIAMI’S COUSIN
92. On Thanksgiving Day, 2022, Mr. Jones was in Mr. Combs' house in Miami, Florida. Yung
Miami and her female cousin (Jane Doe 1) were also present.
93. According to Mr. Jones, Mr. Combs was intoxicated and offered cocaine to Mr. Jones. Mr.
Jones rejected him and proceeded to walk to the restroom.
94. While using the restroom, Yung Miami's cousin burst into the bathroom and began groping
Mr. Jones. Mr. Jones believes that Mr. Combs sent her in there to sexually assault Mr. Jones.
95. According to Mr. Jones, as she entered the bathroom, she dropped to her knees and began
performing oral sex on Mr. Jones' exposed penis. Mr. Jones pushed her away and exited the
bathroom.
96. According to Mr. Jones, Yung Miami's cousin did not accept Mr. Jones rejection, as she
proceeded to follow Mr. Jones out of the bathroom.
97. She started undressing and attempted to straddle him and have sex with him in the presence
of Mr. Combs and his staff.
98. Despite the lack of assistance from Mr. Combs and his staff, Mr. Jones pushed her off. The
following are images from a video13 of Yung Miami, her cousin, Mr. Jones, and Mr. Combs:
9
This writer is in possession of the video and will provide a copy to the court.
10
Upon information and belief, Stevie J denies that he is the person in the video. A male porn star claimed that he
was the black male in the video. Mr. Jones stands by his position that Mr. Combs provided him with the video and
identified the individual in the video as Stevie J.
11
He is a Philadelphia Rapper who dated Nicki Minaj.
12
He performed at the Superbowl and had a successful Vegas residency.
13
19
Mr. Jones and Mr. Combs on Thanksgiving Day right before Mr. Combs invites Mr. Jones
into the restroom and attempted to force him to take cocaine.
Yung Miami, and Jane Doe 1 who sexually assaulted Mr. Jones on
Thanksgiving Day 2022
TRAFFICKING AND VICTIMS’ PROTECTION ACT

99. According to Mr. Jones, he was transported from California to New York, Florida, Saint-
Barthélemy, and the United States Virgin Islands throughout his time with Mr. Combs.
100. According to Mr. Jones, during this time, Mr. Jones was forced to solicit sex workers and
perform sex acts to the pleasure of Mr. Combs.
101. On or about February 4, 2023, Mr. Combs forced Mr. Jones to bring prostitutes and sex
workers back to his home in Miami, Florida.
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Sex Workers In Mr. Jones Bed The Morning After Being Drugged
103. According to Mr. Jones, on another occasion in Miami, Florida, on Thanksgiving night of
2022, Mr. Combs asked Mr. Jones and DeForrest Taylor to enter the studio bathroom.
104. According to Mr. Jones, he asked them for a hundred-dollar bill because he wanted them
to do cocaine with him.
105. Mr. Jones was scared, but luckily, he didn’t have a hundred-dollar bill, so Mr. Combs
waited a little later to do coke with Yung Miami.
106. According to Mr. Jones, later that evening, Mr. Combs required Mr. Jones to solicit sex
workers from Booby Trap on the River, located at 3615 NW S River Dr, Miami, FL 33142.
Mr. Jones did so, and Mr. Combs forced him to engage in unsolicited sex acts with these
workers.
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Booby Trap on the River

107. According to Mr. Jones, as part of Mr. Jones' sex worker recruitment tools, Mr. Combs
provided Mr. Jones with an exclusive Bad Boy baseball cap. They required him to wear it to
Booby Trap on the River as a signal to any sex worker he approached that Mr. Combs was in
town and had sent Mr. Jones to recruit them.
108. According to Mr. Jones, Mr. Jones had no desire to visit Booby Trap on the River. Mr.
Jones had no desire to solicit sex workers from Booby Trap on the River. Mr. Combs used
his power and influence to intimidate and force Mr. Jones into soliciting sex workers from
Booby Trap on the River. As detailed below, Mr. Combs used many tactics to maintain
dominion and control over Mr. Jones.
109. According to Mr. Jones, these workers were accustomed to servicing Mr. Combs and would
know he was in town by the sight of the Bad Boys baseball cap.
110. The following are Instagram Profiles of two of the sex workers that Mr. Combs required
Mr. Jones to solicit and have sex with at his home in Miami, Florida:
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He offered him $250,000.00 to purchase all the instruments he wanted. He promised him
ownership of his $20,000,000 property, 1 Star Island, in Miami, Florida. He promised access
to record label executives.
115. According to Mr. Jones, Mr. Combs would often switch up his approach. He would go
from promising Mr. Jones the world to threatening Mr. Jones with physical harm. Mr. Combs
threatened to eat Mr. Jones' face and informed Mr. Jones that he was willing to kill his mother,
Janice Combs, if he must get what he wanted so he wouldn't think twice about harming Mr.
Jones. In light of Mr. Combs' detailed history of committing violent crimes, Plaintiffs fear of
Mr. Combs is reasonable.
MR. JONES HAS PERSONALLY WITNESSED MR. COMBS AND J. COMBS

SOLICIT, DRUG AND ENGAGE IN ILLICIT SEX ACTS
116. On or about July 2, 2023, Mr. Combs held a "listening party" at his home in California.
117. According to Mr. Jones, present at this party were an R&B artist (REDACTED), J. Combs,
sex workers, and some underaged girls.
118. According to Mr. Jones, the event began at 7 pm. Mr. Combs requested female sex workers
and required Mr. Jones to solicit them. An hour later, several sex workers appeared.
119. According to Mr. Jones, in addition to sex workers, there were at least five women in the
crowd who were under the age of sixteen.
120. According to Mr. Jones, Mr. Combs forced all the women to drink laced DeLeon liquor.
Upon information and belief, Mr. Combs laced the liquor with ecstasy.
121. According to Mr. Jones, Mr. Combs did not check the identification of any of these
underage girls.
122. According to Mr. Jones, the presence of these underage women made him very
uncomfortable14. He attempted to leave, and Mr. Combs forced him to stay.
123. According to Mr. Jones, Mr. Combs went so far as to take Mr. Jones' car keys to prevent
him from leaving.
124. After being forced to drink laced DeLeon shots, Mr. Jones began feeling lightheaded and
recalls passing out and waking up at 4 am the following morning naked with a sex worker
sleeping next to him.
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Plaintiff Jones is in possession of the video and will provide a copy to the court.
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MR. COMBS ATTEMPTS TO PASS OFF MR. JONES TO CUBA GOODING JR.
125. Mr. Jones believes Mr. Combs was grooming him to pass him off to his friends.
126. This fear became a reality when Mr. Combs introduced Mr. Jones to Cuba Gooding Jr.
while they were on Mr. Combs’ yacht.
127. According to Mr. Jones, during the introduction, Mr. Combs suggested that Cuba “get to
know” Mr. Jones better. He then left them alone in a makeshift studio on the yacht15.
Mr. Combs and Cuba Gooding Jr. Moments Before Mr. Jones is Assaulted
128. As evidenced by a video, of which screenshots are embedded below, Cuba Gooding Jr.
began touching, groping, and fondling Mr. Jones’ legs, his upper inner thighs near his groin,
the small of his back near his buttocks, and his shoulders.
129. According to Mr. Jones, he was extremely uncomfortable and proceeded to lean away from
Mr. Gooding Jr.
15
This writer has spoken to an eyewitness who was a former employee of the yacht who confirmed this.
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130. He rejected his advances and Mr. Gooding Jr. did not stop until Mr. Jones forcibly pushed
him away. The following is a screenshot16 of the encounter with Cuba Gooding Jr.:
Cuba Gooding Jr17. Forcibly Touching Mr. Jones on Mr. Combs yacht
THE LOVE ALBUM

131. Throughout his time with Mr. Combs, Mr. Jones was under an implied work-for-hire
agreement.
132. According to Mr. Jones, he was not compensated for his time living with Mr. Combs or for
the songs he produced.
133. According to Mr. Jones, he was recruited by Frankie Santella to work on the Love Album.
Mr. Jones informed Mr. Santella that he required the following to work on the Love Album:
a. $20,000.00 per song,
b. Four royalty points,
c. Credit as producer and credited for each instrument Mr. Jones played, and
d. Mr. Jones must retain his publishing rights.
134. According to Mr. Jones, they agreed to the terms detailed above after meeting with Frankie
Santella. Mr. Jones met with Defendant Combs, who further reiterated and guaranteed that
the abovementioned terms were accepted. As a result, Mr. Jones began working on the album.
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17
Mr. Gooding Jr. has a storied history of sexually assaulting and forcibly touching individuals against their well.
https://www.usatoday.com/story/entertainment/celebrities/2023/11/22/cuba-gooding-jr-lawsuits-sexual-assault-
battery/71682417007/
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135. As evidence, he was listed as a producer for the following songs on the Love Album final
release: Deliver Me, Stay PT 1, Reachin’, What’s Love, Stay Awhile, Moments, Need
Somebody, Homecoming, and Tough Love.
136. Mr. Combs and Defendants LR, MR, and UMG benefited from Mr. Jones’ work product.
137. They failed to compensate Mr. Jones for his work.
138. As a result, Mr. Combs and Defendants LR, MR, and UMG were all unjustly enriched at
Mr. Jones' expense.
139. According to Mr. Jones, he attempted to work with Mr. Combs to secure his publishing and
royalty rights for the work he completed on the Love album. Mr. Combs only offered Mr.
Jones $29,000.00 for 13 months, thousands of hours of work, and nine songs that made it to
the Love album. Mr. Jones was willing to take $50,000.00, his publishing and royalties. Mr.
Combs' self-serving greed would not allow him to pay18 Mr. Jones an additional $21,000.
140. Mr. Combs deceptive business practices became so bad that Mr. Jones was left with no
choice other than to make a public plea on social media for Mr. Combs to pay him for his
work.
141. After publicly requesting that Mr. Combs do the right thing and pay him fairly, Mr. Jones
received an onslaught of threatening messages from Stevie J and Love Records A&R
DeForrest Taylor 19.
18
This writer has retained other creatives, artists, and writers who have experienced this same treatment from Mr.
Combs and will file suit in the coming month.
19
As the A&R of Love Records, DeForrest Taylor did not require Mr. Jones or any of the other creatives, musicians,
or artists to sign an NDA.
28
DeForrest Taylor Threatening Mr. Jones

MR. COMBS USED HIS POWER, AND INFLUENCE TO
THREATEN AND INTIMIDATE MR. JONES
142. According to Mr. Jones, Mr. Combs is very forceful and demanding.
143. According to Mr. Jones, Mr. Combs does not take no for an answer and would often
threaten to inflict bodily harm on Mr. Jones if Mr. Jones did not comply with his demands.
144. As detailed above, Mr. Combs threatened to eat Mr. Jones' face.
145. According to Mr. Jones, on another occasion, while standing in Mr. Combs' bedroom, Mr.
Jones was forced to watch as Mr. Combs displayed his guns and bragged about getting away
with shooting people.
146. According to Mr. Jones, Mr. Combs shared that he was responsible for the shooting in the
nightclub in New York City with rapper Shyne.
29
147. According to Mr. Jones, he shared that artist and Mr. Combs’ girlfriend at the time, Jennifer
Lopez, aka, J-Lo, carried the firearm into the club for him and passed him the gun after he got
into an altercation with another individual.
148. According to a civil complaint filed by Cassie Ventura, during their decade long
relationship, Mr. Combs “demanded that Ms. Ventura to carry his firearm in her purse just to
make her uncomfortable and demonstrate how dangerous he is.”
149. According to Mr. Jones, as was the case with Jennifer Lopez and Ms. Ventura, Mr. Combs
required Brendan Paul and Mr. Jones to carry his firearm on their person whenever they went
out. One of these occasions Mr. Jones was required to carry Mr. Combs' firearm was when
Mr. Combs recorded himself coaching Mr. Jones on how to solicit sex workers.
30
150. According to Mr. Jones, the shooting in Chalice Recording Studios confirmed Mr. Combs'
statements.
151. Based on information and belief, these statements reinforced Mr. Jones's fear of Mr. Combs
and strengthened Mr. Combs's dominion and control over Mr. Jones.
152. Mr. Jones was terrified of Mr. Combs. He felt like he could not tell him no.
153. According to Mr. Jones, Mr. Combs consistently made it clear that he has immense power
in the music industry and with law enforcement.
154. According to Mr. Jones, Mr. Combs made it clear that his head of security, Faheem
Muhammad ("Mr. Muhammad"), had the power to make people and problems disappear.
31
Faheem Muhammad
155. According to Mr. Jones, Mr. Combs instructs his staff to always contact Mr. Muhammad if
the police in Miami or California ever pull them over.
156. Upon information and belief, Mr. Muhammad spoke with the LAPD after G was shot at
CRS. The LAPD was in CRS and witnessed the blood in the restroom, and they went with
the bogus claim that the shooting of G occurred outside of the studio. This was all thanks to
Mr. Muhammad’s connections within law enforcement.
157. Mr. Jones had no reason to disbelieve Mr. Combs as he had seen firsthand through the
shooting of G and the subsequent silence of the LAPD and the media that Mr. Combs indeed
had the power to harm him.
158. he LAPD spent HOURS in CRS after the shooting of G, yet there were no arrests. Mr.
Jones witnessed the LAPD in the restroom pictured above, yet no arrests were made.
159. The morning after the shooting, Mr. Jones and several others arrived at CRS, and G’s blood
was still on the floor of the restroom; Mr. Combs hired a cleaning crew to clean it up.
///
///
///
///
///
///
///
///
///
///
32
DEFENDANT LUCIAN CHARLES GRAINGE IN HIS CAPACITY AS CEO OF UMG,

MOTOWN RECORDS, AND UNIVERSAL MUSIC GROUP THROUGH THEIR
GENERAL BUSINESS PARTNERSHIP, AND
THEIR FINANCIAL SUPPORT OF SEAN COMBS AND LOVE RECORDS, INC.,
AIDED AND ABETTED MR. COMBS ACTIONS AS DETAILED BELOW
160. On March 21, 2024, former Motown Records Chairwoman and CEO Ethiopia
Habtemariam provided Mr. Jones with a Declaration ("Habtemariam Declaration"). (See
attachment B).
161. According to the Habtemariam Declaration, as Motown Records' Chairwoman and CEO,
she reported directly to Defendant Lucian Charles Grainge.
162. According to the Habtemariam Declaration, Motown Records entered into an agreement
with Love Records, Inc., in or around May 2022.
163. According to the Habtemariam Declaration, UMG was aware of and authorized Motown
Records to enter into a license agreement with Love Records.
164. According to the Habtemariam Declaration, under the license agreement, Motown Records
agreed to pay (or reimburse) Love Records for certain of the invoiced recording costs
incurred by Love Records in making The Love Album.
165. According to the Habtemariam Declaration, since leaving Motown Records in November
2022, she has not been involved with Love Records.
166. s detailed throughout this pleading, Plaintiff Jones began working on the Love Album in
September 2022 until it was released in September 2023.
167. According to Mr. Jones, the recording of the Love Album began in Chalice Recording
Studios, where Mr. Combs hosted a nightly party where sex workers and alcohol laced with
drugs were provided.
168. Mr. Jones informed Mr. Combs that the Chalice Recording Studios sessions cost him over
$500,000.
169. In addition to the Chalice Recording Studios recording sessions, The Love Album was
recorded in Mr. Combs' homes in Los Angeles, California, and Miami, Florida.
170. Mr. Jones has a copy of every song recorded for the Love Album, including songs recorded
on the Yacht Mr. Combs and Love Records, Inc., chartered from December 2022 to January
2023.
33
171. According to Mr. Jones, every song has at least five versions, and many other songs never
made it on the Love Album. Each of these files is timestamped and provides a clear timeline
of the creation of The Love Album.
172. According to Mr. Jones, during the creation of the Love Album, Mr. Combs was very
serious about setting the mood and creating a love-making atmosphere. To accomplish this,
Mr. Combs did the following:
a. He installed a lighting system so he could adjust the lighting in the room to red, blue,
pink, or any color he wanted, depending on the mood he was going for.
b. Mr. Combs required everyone working on the Love Album to take shots of Ciroc and
Deleon alcohol. He would instruct either DeForrest Taylor or KK to eliminate them
if they refused. On several occasions, Mr. Combs would send voice notes to the Love
Album phone group chat and pose questions to the group, soliciting their opinions on
Mr. Jones, questioning his loyalty and whether they think he is a good fit for the team.
Mr. Combs knew that Mr. Jones was on the group chat, in his house, and received
those voice notes. After witnessing several people sent home for refusing to engage
in the acts Mr. Combs required to show loyalty, Mr. Jones feared what could happen
to him if he told Mr. Combs no. This is another example of Mr. Combs' grooming of
Mr. Jones.
c. Throughout the creation of the Love Album, Mr. Combs required Mr. Jones and others
to solicit sex workers and engage in sex acts. According to Mr. Jones, Mr. Combs felt
that you cannot make a love album without making love.
173. As the general business partners of Sean Combs and Love Records, Inc., and the financial
backer for the creation of the Love Album, Defendant Lucian Charles Grainge, in his capacity
as CEO of UMG, Motown Records, and Universal Music Group, had a duty to ensure that the
financial support they provided to Sean Combs and Love Records was not being used for sex
workers, drugs, and laced alcohol.
34
174. It is no secret that Mr. Combs had specific bottles of alcohol designated for females, and
other bottles designated for his staff, his artists, and himself. This fact was detailed by former
artists and bodyguards of Mr. Combs.
175. n the YouTube channel The Art of Dialogue, former bodyguard Gene Deal exposed Mr.
Combs's pill-mixing method to spike cranberry juice and orange juice. According to Mr. Deal,
Mr. Combs would place ecstasy20 and other date rape drugs in the juices21.
176. On YouTube, the Art of Dialogue, former artist Mark Curry exposed Mr. Combs spiking
bottles of Moet champagne in the VIP section of night clubs. Mr. Combs would have a set of
Moet champagne bottles for his artists, and a set for women22.
DEFENDANT KRISTINA KHORRAM IS THE GHISLAINE MAXWELL

TO SEAN COMBS JEFFREY EPSTEIN
177. According to Mr. Jones, during the thirteen months he lived and traveled with Mr. Combs,
he witnessed Mr. Combs display and distribute guns from his bedroom closets in Miami,
Florida, and Los Angeles, California, to questionable individuals dressed in all black.
178. According to Mr. Jones, during the thirteen months he lived and traveled with Mr. Combs,
he witnessed Defendant Khorram openly order her assistants to keep Mr. Combs “high” off
gummies and pills23.
179. Defendant Khorram required all employees, from the butler to the chef to the housekeepers,
to walk around with a black Prada pouch or fanny pack filled with cocaine, GHB, ecstasy,
20
This writer has spoken with several former employees of Mr. Combs who witnessed Defendant Khorram instruct
her staff to lace Champagne, DeLeon, and Ciroc liquor bottles with ecstasy and other drugs.
21
https://youtu.be/MFIP8b2IDeg?si=VVM397WmKXlnbHU-
22
https://youtu.be/pjvhfwUmMQw?si=6-5_W6evemGP_AI0
23
We have a recording of this and will provide it to the court.
35
marijuana gummies (100 - 250 mg’s each), and Tuci (a pink drug that is a combination of
ecstasy and cocaine).
TUCI
180. According to Mr. Jones, Defendant Khorram wanted Mr. Combs' drug of choice
immediately ready when he asked for it.
181. According to Mr. Jones, Defendant Khorram ordered sex workers for Mr. Combs. On one
occasion, she sent Mr. Jones a text message requesting that he call a particular sex worker.
We have the message.
182. According to Mr. Jones, Defendant Khorram ordered and distributed ecstasy, cocaine,
GHB, ketamine, marijuana, and mushrooms to Mr. Combs and his celebrity guests, who were
present on his rented yacht and in his homes in LA and Miami.
183. According to Mr. Jones, on multiple occasions, Defendant Khorram forced him to carry
Mr. Combs' drug pouch against his will. The pouches were always black, and several of Mr.
Combs' staff carried black Prada pouches.
184. According to Mr. Jones, Defendant Khorram also sent Mr. Jones to solicit sex workers for
Mr. Combs. When the sex workers arrived at Mr. Combs' residence, Defendant Khorram
would negotiate their price and would take them aside and pay them.
36
Sean Combs Butler, Frankie with the Black Prada Pouch Mentioned Above While On The
Yacht From December 2022 to January 2023
185. As the Chief of Staff, Defendant Khorram was instrumental in organizing and executing
the RICO and TVPA Enterprises. Defendant Khorram had the following individuals execute
the following tasks for the RICO, and TVPA enterprises:
a. Stevie J: Recruits sex workers and attends and participates in freak offs24.
b. Justin Combs: Solicits Prostitutes, Underaged Girls, and Sex Workers. Would
engage in Freak Offs.
c. Brendan Paul: Works as Mr. Combs Mule. He acquires, and distributes, Mr. Combs
Drugs, and Guns.
Brendan Paul and Mr. Combs
d. Frankie Santella25: Works alongside Brendan. While Brendan acquires, and

distributes, Mr. Combs Drugs, and Guns. Frankie carries the money and pays for the
Guns and Drugs.
24
We have a video of Mr. Combs, Stevie J, and Plaintiff Jones at a strip club. Mr. Combs is recording the video,
while coaching and training Plaintiff Jones how to recruit the sex workers.
25
Vice President of Music Management & Strategic Partnerships Vice President of Music Management & Strategic
Partnerships, Combs Global.
37
Frankie Santella and Sean Combs
e. Moy Baun: Hires sex workers, attends and participates in freak offs.
Moy Baun, Thanksgiving 2022 When Mr. Combs Offered Mr. Jones Cocaine.
186. According to Mr. Jones, Mr. Combs funded and used his affiliation with local gangs and
gang leaders26 who would frequent his homes in LA, and Miami to secure the drugs and guns
he obtained and distributed out of his homes in LA and Miami.
26
Plaintiff has intentionally left the names, and images of these individuals out of the pleading out of fear of retaliation.
He will provide the information to the Court under seal or in Camera.
38
187. According to Mr. Jones, Defendants executed their RICO and TVPA Enterprises with
threats of violence: threatening to eat Plaintiff’s face, displaying and distributing guns in
Plaintiff’s presence, bragging about having law enforcement under control, bragging about
murdering people, and bragging about bribing witnesses, and jurors in the criminal case
concerning the 1999 NYC nightclub shooting with Shyne. As a result, Mr. Combs could
maintain dominion and control over Mr. Jones.
188. According to Mr. Jones, Defendants executed his RICO and TVPA Enterprises with threats
of isolation from the music and entertainment industry: parading powerful music industry
executives at his parties filled with sex workers and illegal drugs, such as ecstasy, cocaine,
GHB, ketamine, marijuana, and mushrooms.
189. According to Mr. Jones, Defendant Combs executed his RICO and TVPA Enterprise with
threats of nonpayment for work completed, fake promises of cash payments ($250,000),
producer of the year Grammy awards, and guaranteed access to future projects, and a 20-
million-dollar home on Star Island in Miami.
MR. COMBS IS ALLOWED TO WREAK HAVOC

190. While living and traveling with Mr. Combs, Mr. Jones discovered that Mr. Combs had
hidden cameras in every room of his home.
191. Mr. Jones believes that Mr. Combs has recordings of several celebrities, artists, music label
executives, and athletes engaging in illegal activity at Mr. Combs' functions.
192. Upon information and belief, these individuals were recorded without their knowledge and
consent. As is the case with the homosexual sex tape that Mr. Combs provided to Mr. Jones,
claiming to be Stevie J., Mr. Combs possesses compromising footage of every person who
has attended his freak-off parties and his house parties.
193. Upon information and belief, due to this treasure trove of evidence he has in his possession,
Mr. Combs believes that he is above the law and untouchable.
194. Based on information and belief, Mr. Combs employs Jose Cruz as his IT director. This
writer has spoken to several former employees of Mr. Combs, who confirmed that Jose Cruz
is the gatekeeper to all of Mr. Coms recordings.
39
200. Besides contacting the individual previously mentioned, Mr. Greene contacted Mr.
Jones’s eight-year-old daughter. He solicited information from this child about her father until
she cried in fear and handed the phone to her mother. At that time, her mother hung up the
phone. Mr. Greene proceeded to text her; she informed him that she did not want to be
bothered, and he continued to send her unwanted harassing, text messages.
FIRST CAUSE OF ACTION

CONDUCT AND PARTICIPATE IN A RICO ENTERPRISE
THROUGH A PATTERN OF RACKETEERING ACTIVITY
VIOLATION OF RACKETEER INFLUENCED AND
CORRUPT ORGANIZATION ACT, CODIFIED AT 18 U.S.C. § 1962(A), (C)-(D)
(Against Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, Universal Music Group, Sean Combs, Justin Combs, Kristina Khorram,
Combs Global, and Love Records)
201. Mr. Jones incorporates by reference all preceding paragraphs and re-alleges them as if set
forth fully herein.
202. Defendant Lucian Charles Grainge, in his capacity as CEO of UMG, Motown Records,
and Universal Music Group ("the collective"), is 100% liable for the actions of Sean Combs,
and by extension, Love Records, Combs Global, Justin Combs, and Kristina Khorram ("RICO
orchestrators") as they were acting in their capacities as the collectives' General Business
Partners when they committed the acts detailed below. The collective financially benefited
from Defendants Sean Combs, Combs Enterprises, Love Records, Justin Combs, and Kristina
Khorram through their partnership and distribution deal with Sean Combs and Love Records.
The collective provided Defendants Sean Combs, Combs Enterprises, Love Records, Justin
Combs, and Kristina Khorram with unfettered access to financial resources in the form of
wire transfers, direct payments, and invoice reimbursements and failed to adequately
investigate, supervise, and or monitor where the money was being used, who was using the
money, and what the money was being used for.
203. The financial support provided by the collective was the lifeline that spearheaded and
maintained Defendants Sean Combs, Combs Enterprises, Love Records, Justin Combs, and
Kristina Khorram's depraved actions. Upon information and belief, the establishment and
distribution partnership deal between the collective and Defendants Sean Combs, Combs
Enterprises, Love Records, Justin Combs, and Kristina Khorram was intentionally written
overly broad. For Defendants Sean Combs, Combs Enterprises, Love Records, Justin Combs,
42
and Kristina Khorram to receive financial support from the collective, they had to state that
the payment was for "Love Album Related Expenses." Well, the writer's camp at CRS, the
nightly Club Love parties at CRS, and the yacht were all spaces that Defendants Sean Combs,
Combs Enterprises, Love Records, Justin Combs, and Kristina Khorram utilized to produce
songs that were released on the Love Album. The "Love Album Related Expenses"
reimbursement requirement was a ruse. The collective knew or should have known that
Defendants Sean Combs, Combs Enterprises, Love Records, Justin Combs, and Kristina
Khorram had no intention to utilize the collective's financial support for album-related
expenses, and they did not put any mechanism in place to ensure that the money was not being
used for any illegal activity. The collective's willful blindness resulted in Plaintiff Jones
suffering the harm detailed herein.
204. Defendants are individuals and entities within the meaning of "person" as defined in 18
U.S.C. § 1961(3) because each is capable of holding, and does hold, "a legal or beneficial
interest in property." The association is composed of Lucian Charles Grainge, Sean Combs,
Justin Combs, Kristina Khorram, Combs Global, Motown Records, Love Records, Universal
Music Group, JOHN, and JANE DOES 1-10, and ABC CORPORATIONS 1-10.
205. In the relevant part, 18 U.S. Code 1961 defines a racketeering activity as:
(1) (A) any act or threat involving murder, kidnapping, gambling, arson, robbery, bribery,
extortion, dealing in obscene matter, or dealing in a controlled substance or listed
chemical (as defined in section 102 of the Controlled Substances Act), which is
chargeable under State law and punishable by imprisonment for more than one year; (B)
any act which is indictable under any of the following provisions of title 18,
United States Code: … section 933 (relating to trafficking in firearms), section 1341
(relating to mail fraud), section 1343 (relating to wire fraud), sections 1461–1465 (relating
to obscene matter), section 1511 (relating to the obstruction of State or local law
enforcement), sections 1581–1592 (relating to peonage, slavery, and trafficking
in persons), section 1952 (relating to racketeering), section 1956 (relating to the laundering
of monetary instruments), (D) any offense involving fraud connected with a case under
title 11…the felonious manufacture, importation, receiving, concealment, buying, selling,
or otherwise dealing in a controlled substance or listed chemical.
206. Section 1962(a) makes it:
unlawful for any person who has received any income derived, directly or indirectly,
from a pattern of racketeering activity or through a collection of an unlawful debt in which
such person has participated as a principal within the meaning of Section 2, Title18, United
States Code, to use or invest, directly or indirectly, any part of such income, or the proceeds
of such income, in the acquisition of any interest in, or the establishment or operation of,
43
any enterprise which is engaged in, or the activities of which affect interstate or foreign
commerce. 18 U.S.C. § 1962(a).
207. Section 1962(c) makes it:
unlawful for any person employed by or associated with any enterprise engaged in, or the
activities of which affect, interstate or foreign commerce, to conduct or participate, directly
or indirectly, in the conduct of such enterprise’s affairs through a pattern of racketeering
activity. 18 U.S.C. §1962(c).
208. Section 1962(d) makes it:
unlawful for “any person to conspire to violate” Section 1962(a) and (c), among other
provisions. 18 U.S.C. § 1962(d).
209. Defendants are associated with each other as an enterprise within the meaning of
“enterprise” as defined in 18 U.S.C. § 1961(4).
210. Throughout this pleading, Mr. Jones has detailed many acts by Defendants Sean Combs,
Combs Enterprises, Love Records, Justin Combs, and Kristina Khorram, which are prohibited
under 18 U.S.C. §1962.
211. Defendants have unlawfully increased their profits by luring and deceiving producers,
musicians, writers, creators, and artists such as Plaintiff to their organization for the misstated
purpose of using their talents as creatives to produce music. Defendants’ true intentions are
later revealed through a calculated grooming scheme that involves false promises of business
opportunities, exposure to music executives with the promise of future introductions, and the
promise of awards and accolades, which quickly shifts to unauthorized drugging, threats of
bodily harm, sex trafficking, and sleep deprivation. According to Mr. Jones, Defendant
Combs often required Mr. Jones to work for several consecutive days without sleep.
According to Mr. Jones, it was imperative always to look like he was working whenever Mr.
Combs walked by.
212. Within a few months of working for and living with Mr. Combs, Mr. Jones witnessed KK
instruct her direct reports and Combs enterprise employees Brendan, Frankie, and Moy to
acquire and transport the following drugs: ecstasy, cocaine, GHB, ketamine, marijuana, and
mushrooms. Mr. Jones personally witnessed Combs Enterprise employee Brendan transport
firearms to and from nightclubs, strip clubs, and other venues for Mr. Combs on his person in
Miami, Florida. Mr. Jones personally witnessed Mr. Combs distribute firearms out of his
bedroom closet to individuals that Mr. Jones knew to be members of local gangs28. During
28
Plaintiff is intentionally being vague, in fear of his personal safety. He can provide more detail to the Court in
camera.
44
the making of the Love Album, several evenings, Mr. Jones personally witnessed Mr. Combs
instruct the Combs enterprise employees Brendan, Frankie, and Moy to solicit sex workers to
the recording studio at his homes and to the Chalice Recording Studios. According to Mr.
Jones, Mr. Combs felt there was too much testosterone in the studio and wanted sex workers
there to create the vibe for the Love Album. Then these workers arrived, and Mr. Jones and
the other musicians and producers were required to engage in sex acts with them. KK and
Frankie would often negotiate the price for the sex workers' services. They would either pay
the workers in cash, electronically (cash app, Venmo, PayPal, or wire transfers), or through
any other form requested by the sex worker. As detailed in the chart below, when Mr. Jones
was groomed into soliciting sex workers for Mr. Combs, he often negotiated the cost via text
message.
213. The RICO enterprise, which all Defendants have engaged in, and the activities of which
affected interstate and foreign commerce, is comprised of an association, in fact, of persons,
including each Defendant and other unnamed co-conspirators. That association was
structured by various general partnership agreements, establishment deals, distribution deals,
contracts, and non-contractual relationships between the Defendants, by which Defendants
assumed different roles in either knowingly or negligently funding, directly or indirectly
participating in the acts necessary to carry out a scheme to acquire and distribute drugs,
firearms, prostitutes, and sex workers. They also worked collectively to deceptively obtain
the labor of producers, musicians, writers, creators, and artists such as Plaintiff to utilize their
talents and labor to produce music and other tangible goods and services without full
compensation. As detailed herein, Plaintiff Jones worked for Mr. Combs for thirteen months.
Combs Enterprise employee Frankie solicited him to produce the Love Album. Frankie and
Mr. Combs agreed to provide Mr. Jones $20,000.00 per song, four royalty points per song,
credit as producer, credit for each instrument Mr. Jones played, and publishing rights for Mr.
Jones' work in exchange for Mr. Jones' services on The Love Album. Over thirteen months,
Mr. Jones fulfilled his end of the agreement and provided services for the Love Album. Mr.
Combs benefited from Mr. Jones' services and refused to compensate him by their agreement.
Mr. Jones is not the only creative who had his services stolen by Mr. Combs; many creatives
worked for months on the Love Album and were never compensated for their work.
45
214. According to the Habtemariam Declaration, the collective reimbursed or paid for the
production of the Love Album. Mr. Jones was not compensated, so if the Habtemariam
Declaration is correct, what was the collective financial support used for? And what
mechanism did the collective have in place to ensure the money provided to Defendants Sean
Combs, Combs Enterprises, Love Records, Justin Combs, and Kristina Khorram were used
for the purposes outlined in the collective's partnership deal with Defendants Sean Combs,
Combs Enterprises, Love Records, Justin Combs, and Kristina Khorram.
215. The collective and Defendants Sean Combs, Combs Enterprises, Love Records, Justin
Combs, and Kristina Khorram all share a common purpose: to use deception, coercion, force,
and the threat of violence to enrich themselves at the expense of individuals like the Plaintiff.
As set forth herein, although members of the collective may not have directly threatened
coerced, force or violently threaten Plaintiff, they financially benefitted from Defendants Sean
Combs, Combs Enterprises, Love Records, Justin Combs, and Kristina Khorram scheme of
defrauding, and intimidating the Plaintiff with threats of violence (threatening to eat Plaintiff's
face, displaying and distributing guns in Plaintiff's presence, bragging about having law
enforcement under control, bragging about murdering people, and bragging about bribing
witnesses, and jurors in the criminal case concerning the 1999 NYC nightclub shooting with
Shyne), threats of isolation from the music and entertainment industry (parading influential
music industry executives at Mr. Combs parties filled with sex workers, minors, and illegal
drugs, such as ecstasy, cocaine, GHB, ketamine, marijuana, and mushrooms), threats of
nonpayment for work completed, fake promises of cash payments ($250,000), producer of the
year Grammy awards, guaranteed access to future projects, and a $20 million dollar home on
Star Island in Miami. It is reasonable to believe Defendants Sean Combs, Combs Enterprises,
Love Records, Justin Combs, and Kristina Khorram would not have engaged in these acts of
threats but for the existence of the Rico scheme and their understanding that the collective
would provide unfettered access to financial recourses without ever questioning Defendants
Sean Combs, Combs Enterprises, Love Records, Justin Combs, and Kristina Khorram use of
the money.
216. Upon information and belief, the collective and Defendants Sean Combs, Combs
Enterprises, Love Records, Justin Combs, and Kristina Khorram have had several
partnerships throughout the years. As is the case here, Defendant UMG provided Mr. Combs
46
with unfettered access to financial dollars in exchange for Mr. Combs and Defendants Sean
Combs, Combs Enterprises, Love Records, Justin Combs, and Kristina Khorram providing
Defendant UMG with the fruits of the labor of producers, musicians, writers, creators, and
artists such as Plaintiff to utilize their talents and labor to produce music, and other tangible
goods and services without full compensation.
Date of Partnership Participants in the Partnership Details of the Partnership
2003 to 200529 Sean Combs, Bad Boy Joint Venture
(3 years) Records, and Universal
Music (subsidiary of
Defendant UMG)
2009 to 2015 Sean Combs, Bad Boy Worldwide Distribution Deal
(6 years) Records, and
Universal/Interscope Geffen
A&M (subsidiary of
Defendant UMG)30
2022 to 2023 Sean Combs and Motown Establish Love Records and
(approx. 1 year) Records (subsidiary of distribute the Love Album
Defendant UMG)31
217. As outlined in the chart above, from 2003 to 2005, Defendant Combs, the then CEO and
owner of Bad Boy Records, entered a joint venture deal with Universal Music, a subsidiary
of Defendant Universal Music Group. Upon information and belief, at the time Defendant
Combs and UMG entered their three-year joint venture, it was public knowledge that Mr.
Combs had a serious reputation for violence and engaging in criminal activity. Defendant
UMG had firsthand knowledge of Combs' propensity for violence because on April 16, 1999,
Defendant Combs assaulted Steve Stoute, their Executive Vice President of Interscope Geffen
A&R. Combs was arrested and charged with two felonies — second-degree assault and
criminal mischief — in the beating of Steve Stoute, who says Combs and two bodyguards
beat him with their fists, a telephone, a champagne bottle, and a chair. Mr. Combs had a
criminal trial surrounding the 1999 Nightclub shooting in NYC, when Mr. Combs required
his then-girlfriend, Jennifer Lopez, to transport his illegal firearm into the NYC nightclub. In
29
https://www.nytimes.com/2003/02/08/business/p-diddy-signs-3-year-deal-with-universal-records.html
30
“Puff is a rare person in the music industry today, that can move the culture in many areas – fashion, TV, music –
as well as making records,” commented IGA Chairman Jimmy Lovine. “Whenever a free agent like him comes along,
which is rare, you grab him.”
31
https://www.ebony.com/diddy-launches-new-rb-label-in-partnership-with-motown-records/ and
https://www.motownrecords.com/culture/diddy-and-motown-partner-up/
47
2001, Former television host Roger Mills sued Mr. Combs for assault. This case did not end
until 2004, two years into the joint venture deal. Despite all these public warning signs of a
pattern and practice of behavior that evidence a propensity to engage in violent crimes and
other criminal activity, Defendant UMG chose to enter into a general partnership agreement
with Mr. Combs. Defendant UMG knew or should have known that it had a duty to monitor
how the financial resources they provided to Mr. Combs were being spentUpon information
and belief, from 2009 to 2015, the collective and Defendants Sean Combs, Combs Enterprises,
Love Records, Justin Combs, and Kristina Khorram32 continued their Rico enterprise when
Mr. Combs, UMG and Mr. Grainge entered a general business partnership to internationally
distribute music produced by Mr. Combs and Bad Boy Records. As part of that deal UMG
provided financial support to Mr. Combs and paid for all expenses related to the development
and distribution of the music Mr. Combs and Bad Boy Records produced.
218. On or about 2022 to 2023, the collective and Defendants Sean Combs, Combs Enterprises,
Love Records, Justin Combs, and Kristina Khorram established the latest iteration of their
RICO enterprise when they entered a general business partnership to establish Love Records
and to distribute Love Records first album, the Love Album off the Grid. According to the
Declaration of Ms. Habtemariam, as the Chairwoman and CEO of Motown Records, she
reported directly to Defendant Lucian Grainge. Ms. Habtemariam also states that she was
given approval by Defendant UMG to enter the partnership with Sean Comes to help establish
Love Records. It is safe to assume that Defendant Lucian Grainge, Ms. Habtemariam's direct
supervisor, was aware of and signed off on the UMG and Sean Combs partnership, which led
to the establishment of Love Records. According to Ms. Habtemariam, Defendants UMG and
MR financed Sean Combs for "approved" invoices associated with the creation of the Love
Album. Ms. Habtemariam did not identify any mechanism MR or UMG implemented to
ensure the financial support remitted to Mr. Combs and Love Records went to approved
invoices associated with the Love Album. If the treatment of Plaintiff Jones is any indication
of how Defendants UMG and MR ensured that their financing of Love Records and the Love
Album was applied in accordance with the partnership agreement, then they would have
32
Upon information and belief, Defendant Kristina Khorram began her employment with Defendant Combs, and
Combs Enterprises in 2013.
48
realized that artists like Plaintiff Jones had worked for several months on the Love Album
without full compensation.
219. Upon information and belief, if the collective financed Defendants Sean Combs, Combs
Enterprises, Love Records, Justin Combs, and Kristina Khorramin in the manner described
by Ms. Habtemariam's declaration, then it is safe to assume that they financed the "recording
costs" at Chalice Recording Studios, Defendant Combs houses in Miami and Los Angeles, as
well as the Yacht as evidenced by posts Mr. Combs made on his Instagram page from
September 2022 to September 2023 (on or about the time the Love Album was released), as
well as the videos, and photos in Mr. Jones possession, Defendants Sean Combs, Combs
Enterprises, Love Records, Justin Combs, and Kristina Khorram did more than just record
music. On a daily basis, Defendants Sean Combs, Combs Enterprises, Love Records, Justin
Combs, and Kristina Khorram had sex workers and endless drugs flowing through the
recording sessions at CRS, Mr. Combs' homes, and on the Yacht which Mr. Combs rented.
Unless the collective had an overseer present at the recording sessions to account for how the
money they provided Defendants Sean Combs, Combs Enterprises, Love Records, Justin
Combs, and Kristina Khorramwas being spent, it is safe to say they were complicit in allowing
their money to pay for illegal drugs, and sex workers.
220. As evidenced by the hundreds of hours of video and audio recordings in Plaintiff's
possession, Defendants Sean Combs, Justin Combs, Kristina Khorram, his assistants, and staff
all orchestrated, participated, managed, and executed the RICO Enterprise by purchasing and
distributing ecstasy, cocaine, GHB, ketamine, marijuana, and mushrooms. They transported
the drugs by flying on commercial airlines from California to New York, Florida, the Virgin
Islands, and Saint Barthélemy in the French Caribbean. They placed these controlled
substances in their carry-on luggage through TSA. They then carried these substances in
black pouches and distributed the drugs to Mr. Combs, his friends, house guests, girlfriends,
and sex workers.
221. The RICO enterprise has functioned as a continuing unit and maintains an ascertainable
structure separate and distinct from the pattern of racketeering activity.
222. Upon information and belief, the enterprise was characterized by the collective providing
unlimited, unchecked financing to Defendants Sean Combs and Love Records for the
establishment of Love Records and the creation of the Love Album. Defendants Sean Combs,
49
Love Records, and Kristina Khorram had a pattern of making false representations and
omissions to the artists, creatives, musicians, and producers who used their talents to provide
services to the RICO enterprise. These false representations and omissions were designed to
induce artists, creatives, musicians, and producers to utilize their talents and labor to produce
music and other tangible goods and services without full compensation. These artists,
producers, creatives, and musicians were also forced to solicit and participate in sexual
encounters with prostitutes and sex workers. They were also required to transport illegal,
unregistered handguns and to purchase and distribute narcotics.
223. As part of this scheme, Defendants required their artists, creatives, musicians, and
producers to visit strip clubs wearing exclusive authentic Bad Boy merchandise and to use the
name and reputation of Mr. Combs to solicit sex workers and prostitutes.
Mr. Jones and Brendan wearing the Bad Boy Hat

224. Additionally, Mr. Combs used the prospects of winning Grammy awards, purchasing 20-
million-dollar homes, participating in future projects, making $250,000 cash payments, and
meeting influential music industry executives. This pattern of false representations was
disseminated to artists, creatives, musicians, and producers who reside in California, Florida,
New York, and around the country by Defendants based in California, Florida, and New York
50
under the direction and on behalf of Defendants in New York. The dissemination typically
used interstate telephone wires, social media messages, and electronic mail.
225. Upon information and belief, the true nature of Defendants’ scheme was left undisclosed,
was omitted, and/or was affirmatively misrepresented, all to fraudulently increase Defendants’
profits, at least some of which were used to expand the enterprise, causing further injury to
Plaintiff Jones and other unwitting artists, creatives, musicians, and producers.
226. Upon information and belief, Defendants profited from the enterprise, and Plaintiff Jones
suffered because the enterprise diminished Plaintiff Jones's finances due to 13 months of
nonpayment and diminished Plaintiff Jones's health through consistent drugging and forced
sexual encounters with prostitutes and sex workers. Defendants used the proceeds from this
scheme to advance the scheme by funding and operating their marketing machine, including
through the use of the mail, social media, word of mouth, and interstate wires to sell the
illusion that Mr. Combs was serious about the talents and skills of the artists, creatives,
musicians, and producers, and wanted to use those skills to make music when nothing could
be further from the truth. Defendants provided their artists, creatives, musicians, and
producers with this misrepresentative information, including via email all over interstate
wireline communications systems and obtaining free labor, the distribution of drugs and
firearms, as well as prostitutes, sex workers, and minors. Defendants obtained revenue via
wire transfers, documents, and banking transactions that were exchanged via electronic means
over interstate wires, thereby growing the enterprise and causing further injury to Plaintiff
Jones as described throughout.
227. Upon information and belief, The Defendants' scheme was reasonably calculated to
deceive Plaintiff Jones, artists, creatives, musicians, and producers of ordinary prudence and
comprehension through the execution of their complex and illegal scheme to misrepresent the
effectiveness of soliciting prostitutes, sex workers, and minors and distributing drugs and guns
that did not, would not, and could not lead to securing Grammy Awards, purchasing $20
million homes, participating on future projects, $250,000 cash payments, and meeting
influential music industry executives. Plaintiff Jones would not have lived with Mr. Combs
for 13 months, missing birthdays, holidays, and family events, but for the illegal racketeering
scheme operated by Defendants.
51
228. Upon information and belief, Defendants each had the specific intent to participate in the
overall RICO enterprise and the scheme to defraud Plaintiff Jones, and each participated in
the enterprise as follows:
229. Upon information and belief, Defendants Lucian Charles Grainge, Combs Global, Motown
Records, Love Records, and Universal Music Group control and participate in the activities
of the enterprise in a variety of ways as set forth herein, including but not limited to developing
and marketing scores of writing camps, and listening parties services that are marketed to
innocent, unassuming artists, creatives, musicians, and producers who are.
230. Throughout the relevant period, Defendant Lucian Charles Grainge in his capacity as CEO
of UMG, authorized Motown Records and Universal Music Group to enter into a general
partnership agreement with Sean Combs and Love Records. As general business partners,
each member is responsible for the partners' actions in the partnership. Defendants Lucian
Charles Grainge, Motown Records, and Universal Music Group have an ethical obligation to
ensure their business partners, Sean Combs and Love Records, were not using the partnership
assets to engage in illegal activity.
231. Defendants Lucian Charles Grainge, in his capacity as CEO of UMG, authorized Motown
Records and Universal Music Group to provide financial resources to their general business
partners, Defendants Sean Combs and Love Records. Defendants Sean Combs and Love
Records used the financial resources provided by their general business partners to solicit
through the mail, email, social media, and the telephone artists, creatives, musicians, and
producers whom they would promise Grammy Awards, expensive property, participation on
future projects, cash payments, and meetings with powerful music industry executives.
Defendants Sean Combs and Love Records instructed Defendants Justin Combs, Kristina
Khorram, and her staff to solicit these artist's creatives, musicians, and producers who resided
in New York, Illinois, California, Georgia, and Florida. Defendants Justin Combs, Kristina
Khorram, and her staff relied on the mail, email, social media messenger, and telephone to
disseminate the misleading information described herein. Defendants Sean Combs, Love
Records, Justin Combs, and Kristina Khorram did not disclose to the individuals they solicited
the fact that they would be drugged, required to sleep with sex workers, and forced to work
for days at a time without compensation. As it relates to Plaintiff Jones, Defendants Sean
Combs, Love Records, and Kristina Khorram controlled his ability to travel. They did not
52
provide him with full compensation for the work he provided. As a result, Mr. Jones did not
have the finances to return home without Defendants Sean Combs, Love Records, and
Kristina Khorram paying for it. On several occasions in Miami, Florida, he asked Defendants
Sean Combs and Kristina Khorram for permission to visit his family for their birthdays and
holidays. Defendants Sean Combs and Kristina Khorram refused. They went so far as
threatening Mr. Jones by telling him that if he left, he would not be paid for the work he had
done, would not be allowed to return, and would not receive the promised Grammy Awards,
expensive property, participation in future projects, cash payments, and meetings with
influential music industry executives.
232. In connection with Defendants acting from New York, these Defendants used the mail and
interstate wires to solicit Plaintiff Jones and artists, creatives, musicians, and producers and
to use Plaintiff Jones and the artists, creatives, musicians, and producers to utilize their talents
and labor to produce music, and other tangible goods and services without full compensation,
as well as the solicitation of sexual encounters with prostitutes, sex workers, and the
purchasing and distribution of illegal firearms and drugs. Each of these acts was undertaken
with the knowledge and approval of all other Defendants to further the goals of their
conspiracy.
233. Defendants Lucian Charles Grainge, in his capacity as CEO of UMG, authorized Motown
Records and Universal Music Group to provide financial resources to their general business
partners, Defendants Sean Combs and Love Records. As the financial supplier of Defendants
Sean Combs and Love Records, Defendants Lucian Charles Grainge, in his capacity as CEO
of UMG, Motown Records, and Universal Music Group, had a duty to direct and control the
manner in which Defendants Sean Combs and Love Records, used the money they supplied.
In furtherance of the goals of their conspiracy, Defendants Lucian Charles Grainge, in his
capacity as CEO of UMG, Motown Records, and Universal Music Group, used the Love
Album as a ruse to provide Defendants Sean Combs and Love Records with the financial
resources he used to execute his RICO enterprise. Throughout the relevant period, Defendants
Sean Combs and Love Records used the financial resources their general business partners
provided to solicit potential artists, creatives, musicians, and producers. As detailed
throughout, they relied on the mail, email, social media, text messages, and WhatsApp
messages to disseminate the misleading information described herein and profit from the free
53
labor of these artists, creatives, musicians, and producers. In addition to the forced free labor,
they used their power and influence to force these creatives to solicit sex workers and to
engage in unwanted sexual encounters with these sex workers. They also used their power
and influence to force these creatives to purchase, transport, and distribute illegal firearms
and drugs. As the general business partner of Defendants Sean Combs and Love Records,
Defendants Lucian Charles Grainge, in his capacity as CEO of UMG, Motown Records, and
Universal Music Group, are equally liable for the commission of these acts.
234. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as CEO
of UMG, authorized Motown Records and Universal Music Group to provide financial
resources to Defendants Sean Combs and Love Records through wire transfers to Defendants
Sean Combs and Love Records accountant Robin Greenhill. Upon information and belief,
Ms. Greenhill ensured the wiring, funds transfer, or cash payments to sex workers were
completed. Defendant Kristina Khorram, through her direct reports Frankie Santella, Moy
Baun, and Brendan Paul, would negotiate the fees the sex workers received and would ensure
that the workers are paid in one of the manners detailed above. According to Plaintiff Jones,
Defendant Sean Combs bragged about having several women on a monthly stipend.
According to Plaintiff Jones, the women who received these payments are Caresha Romeka
Brownlee, aka "Yung Miami," Jade Ramey, aka "Jade," and Daphne Joy Cervantes Narvaez,
aka, "Daphne Joy" who were paid a monthly fee to work as Mr. Combs' sex workers. Based
on information and belief, they received payment via wire transfer from Robin Greenhill. It
is unclear if they were provided the appropriate United States federal tax documents for these
payments or if they independently declared these payments on their taxes. It is unclear if
Universal Music Group, requested an audit of Defendants Sean Combs and Love Records'
financial records to ensure the financial support they provided to Defendants Sean Combs and
Love Records as part of their general business partnership was not being used to pay Caresha
Romeka Brownlee, Jade Ramey, and Daphne Joy Cervantes Narvaez.
235. During the ten (10) years preceding the filing of this action and to the present, all
Defendants did cooperate jointly and severally in the commission of three (3) or more of the
predicate acts that are itemized at 18 U.S.C. §§ 1961(1)(A) and (B), in violation of 18 U.S.C.
1962(d), as described in this Complaint.
54
236. Beginning at an exact date unknown to Plaintiff, but within ten (10) years preceding the
filing of this action, Defendants have knowingly, willfully, and unlawfully participated in a
pattern of racketeering activity that continues to this day.
237. The acts set below ("Racketeering Acts") followed the same pattern and purpose: to defraud
the Plaintiff for the Defendants' benefit. Each Racketeering Act involved the same or similar
methods of commission and participants.
238. The Defendants' business would not have succeeded without the repeated predicate acts
and the ability to conduct their fraud using mail, telecommunications wires, interstate travel,
international travel, and money laundering.
239. The separate Racketeering Acts all relate to each other in that they were part of concerted
actions by Defendants to use the endorsement and channels of the enterprise to operate their
businesses to solicit potential artists, creatives, musicians, and producers. As detailed
throughout, they relied on the mail, email, social media, text messages, and WhatsApp
messages to disseminate the misleading information described herein and profit from the free
labor of these artists, creatives, musicians, and producers. In addition to the forced free labor,
they used their power and influence to force these creatives to solicit sex workers and to
engage in unwanted sexual encounters with these sex workers. They also used their power
and influence to force these creatives to purchase, transport, and distribute illegal firearms
and drugs.
240. The separate Racketeering Acts all relate to each other in that they were part of concerted
actions by Defendants to use the endorsement and channels of the enterprise to operate their
businesses to fraudulently induce Plaintiff Jones and the artists, creatives, musicians, and
producers to utilize their talents and labor to produce music, and other tangible goods and
services without full compensation. In addition to the forced free labor, they used their power
and influence to force these creatives to solicit sex workers and to engage in unwanted sexual
encounters with these sex workers. They also used their power and influence to force these
creatives to purchase, transport, and distribute illegal firearms and drugs.
241. The Defendants' wrongful conduct has injured Plaintiff Jones, remains part of their ongoing
business practices, and continues to threaten Plaintiff Jones and the public.
55
242. Defendants' association with the enterprise enabled Defendants to conduct, direct, and
control a pattern of fraudulent, illegal activities over a substantial number of years, which
continues to this day.
243. To further their goals, Defendants worked in concert to engage in various forms of criminal
activity, including the solicitation of sexual encounters with sex workers and the purchasing
and distribution of illegal firearms and drugs.
244. The defendant's ongoing racketeering activity has injured and continues to injure Plaintiff
Jones. The Defendants' pattern of forcing Plaintiff Jones and the artists, creatives, musicians,
and producers to solicit sexual encounters with sex workers and to purchase, transport, and
distribute illegal drugs and firearms was the proximate cause of the injuries suffered by
Plaintiff.
Defendants Committed Multiple Acts of Sex Trafficking in Violation of 18 U.S.C. § 1591 (Sex
trafficking of children or by force, fraud, or coercion) in Furtherance of the Enterprise
245. As detailed throughout this pleading, Defendants Sean Combs, Love Records, Combs
Enterprises, Justin Combs, Kristina Khorram, through her direct reports Frankie Santella,
Moy Baun, and Brendan Paul knowingly affected interstate or foreign commerce, or within
the special maritime and territorial jurisdiction of the United States, by recruiting, enticing,
harboring, transporting, providing, obtaining, advertising, maintaining, patronizing, or
soliciting by any means a person (Plaintiff Jones) to engage in illegal sex acts. In addition to
violating federal law, these acts violated the following state statutes: Florida, Penal Code
796.07(2)(f); California, Penal Code 647(b); New York, Penal Code 230.05; and USVI, Penal
Code tit. 14, § 1622.
246. In addition to violation of laws in the United States territory, Defendants Sean Combs,
Love Records, Combs Enterprises, Justin Combs, Kristina Khorram, through her direct
reports Frankie Santella, Moy Baun, and Brendan Paul’s actions, may have violated the laws
of Saint-Barthélemy.
247. As detailed throughout this pleading, Defendants Lucian Charles Grainge, in his capacity
as CEO of UMG, authorized Motown Records and Universal Music Group to provide
financial resources to Defendants Sean Combs and Love Records. Through their general
business partnership, Defendants Lucian Charles Grainge, in his capacity as CEO of UMG,
Motown Records, Universal Music Group, Love Records, Sean Combs, and by extension
through Sean Combs, Justin Combs, Combs Enterprises, and Kristina Khorram knowingly
56
benefited, financially or by receiving anything of value, in a venture which has engaged in an

act described in violation of paragraph (1) of 18 U.S.C. § 1591.
248. Defendants Love Records, Kristina Khorram, Sean Combs, and by extension through Sean
Combs, Justin Combs, and Combs Enterprises knowingly, or, except where the act
constituting the violation of paragraph (1) 18 U.S.C. § 1591 advertised, in reckless disregard
of the fact, that means of force, threats of force, fraud, coercion described in subsection (e)(2)
of 18 U.S.C. § 1591, or any combination of such means will be used to cause Plaintiff Jones
to engage in several commercial sex acts.
249. By way of example, on or about January 28, 202333, Plaintiff Jones34 was residing in
Defendant Combs' home at 2 Star Island Drive in Miami, Florida. Defendants Sean Combs
and Kristina Khorram forced Mr. Jones to send Ubers to transport a sex worker to Mr. Combs'
home located at 2 Star Island Drive in Miami, Florida. We have the complete text thread and
have intentionally opted not to include it here to protect the identity of this sex worker.
Defendant Combs forced Mr. Jones to have sex with this individual against his will.
According to Mr. Jones, Defendant Combs felt there was too much testosterone in the studio
and wanted sex workers there to create the vibe for the Love Album. Upon information and
belief, this Uber and this sex worker were compensated from the financial support Defendants
Lucian Charles Grainge, in his capacity as CEO of UMG, authorized Motown Records and
Universal Music Group to provide to Sean Combs and Love Records for the recording costs
associated with the creation of the Love Album.
33
According to Counsel for Defendants Lucian Charles Grainge, Motown Records, and Universal Music Group, they
ended their general business partnership agreement with Mr. Combs and Love Records at some point during the month
of February 2023.
34
In the interest of preserving Plaintiff Jones Fifth Amendment rights, we will provide the remaining text messages,
and voice memos to the Court in Camera. It is important for the Court to remember that Plaintiff was coerced through
threats of violence to engage in these acts. Additionally, Defendants Khorram and Sean Combs controlled the purse,
and would only allow Plaintiff to leave their custody and control based on their terms.
57
252. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt
acts, among others, were committed in the States of New York, California, Florida, the USVI,
and elsewhere:
a. In or about September 2022, Defendant Sean Combs, through his authorized agent,
Frankie Santella, recruited Plaintiff Jones to work for him as a producer, musician, and
creative for Love Records. Defendant Combs promised to pay Mr. Jones the following
to work on the Love Album: $20,000.00 per song, four royalty points, Credit as
producer, and Credit for each instrument Mr. Jones played. Mr. Jones must retain his
publishing rights.
b. In or about September 2022, Defendant Sean Combs began slowly grooming Plaintiff
Jones by directly35 teaching Mr. Jones how to go about recruiting sex workers. He
provided Mr. Jones with a Bad Boy Baseball cap, instructed his agents Stevie J., and
Moy Baun to teach Plaintiff Jones the type of sex workers to solicit, and way to solicit
them.
c. As part of his grooming of Plaintiff Jones, in or about December 2022, while on a
Yacht, Defendant Combs bragged about and detailed how he got away with a New
York City nightclub shooting in 1999. In or about January 2023, while in his home in
Miami, Defendant Combs required Mr. Jones to work out of his bedroom and watch
as Defendant Combs distributed guns to individuals dressed in all black. In or about
April 2023 in Los Angeles, Defendant Combs required Mr. Jones to work out of his
bedroom and watch as Defendant Combs distributed guns to individuals that Mr. Jones
knew to be members of a local gang. In or about April 2023, Defendant Combs
threatened to eat Mr. Jones' face and informed him that he would not hesitate to kill
his own mother to get what he wanted.
d. As evidenced by the chart below, at the direction of Defendants Combs and Kristina
Khorram, Plaintiff Jones was forced to solicit the identified sex workers. These
workers were brought to Mr. Combs' homes at 2 Star Island Drive in Miami, Florida,
and 1 Star Island Drive in Miami, Florida. Plaintiff Jones had no authority to invite
guests to Defendant Combs' home without either Defendant Combs' or Defendant
35
We have a recording, taken my Mr. Combs at a club in Miami Florida. This was the night that Mr. Combs personally
taught Mr. Jones how to solicit sex workers. We will provide a copy of the video to the court in camera.
60
Kristina Khorram's consent. Defendant Combs property is protected by 24-hour

security, and all visitors must be verified before entry:
Sex Workers and last Dates of forced Location
two digits of their solicitation
cellphone
Sex Worker 1 (98) 1/30/23, 1/31/23, 2/1/23, 2 Star Island Drive in
2/2/23 Miami, Florida.
Sex Worker 2 (87) 2/8/23, 2/9/23, 4/4/23 2 Star Island Drive in

Miami, Florida
Sex Worker 3 (82) 11/29/22, 1/26/23, 2 Star Island Drive in

2/2/23, 2/4/23 Miami, Florida

12/2/22 Miami, Florida
Sex Worker 5 (77) 2/1/23, 2/2/23, 2/4/23, 2 Star Island Drive in

2/5/23 Miami, Florida
Sex Worker 6 (43) 1/28/23, 1/28/23 2 Star Island Drive in

Miami, Florida

1/26/23, 1/27/23, Miami, Florida, and
1/29/23, 1/30/23, 4/1/23, 1 Star Island Drive in
5/5/23, 5/6/23, 5/7/23, Miami, Florida
5/8/23,
Sex Worker 8 (72) 5/8/23 2 Star Island Drive in

Miami, Florida
253. From at least in or about September 2022, up to and including in or about November 2023,
in the States of New York, California, Florida, the USVI, and elsewhere, Defendants Sean
Combs and Kristina Khorram and others known and unknown, in and affecting interstate
commerce, knowingly did recruit, entice, harbor, transport, provide, obtain, and maintain, by
any means a person (Plaintiff Jones), and did benefit, financially and by receiving anything
of value, from participation in a venture which has engaged in any such act, knowing and in
reckless disregard of the fact that means of force, threats of force, fraud and coercion, and a
combination of such means, would be used to cause the person to engage in a commercial sex
act, to wit, Defendants Sean Combs and Kristina Khorram caused Plaintiff Jones to engage in
61
commercial sex acts utilizing force, threats of force, fraud and coercion, and a combination
of such means. Additionally, Defendant Combs received personal gratification by watching
Plaintiff Jones engage in commercial sex acts with the aforementioned sex workers.
254. From at least in or about September 2022, up to and including in or about November 2023,
in the States of New York, California, Florida, the USVI, and elsewhere, Defendants Sean
Combs and Kristina Khorram and others known and unknown, in and affecting interstate
commerce, did use and cause to be used facilities in interstate and foreign commerce, to wit
internet and cellular telephone services, with the intent to promote manage, establish, carry
on and facilitate the promotion, management, establishment and carrying on of an unlawful
activity, to wit, a business enterprise involving prostitution offenses in violation of applicable
state law, and thereafter performed and attempted to perform an act to promote, manage,
establish and carry on, and to facilitate the promotion, management, establishment and
carrying on of such unlawful activity.
Defendants Committed Multiple Acts of procuring, transporting, and distributing controlled

substances in Violation of Title 18, United States Code, Sections 1961(1) and 1961(5)
Furtherance of the Enterprise
255. As detailed throughout this pleading, Defendants Sean Combs, Love Records, Combs
Enterprises, Justin Combs, Kristina Khorram, through her direct reports Frankie Santella,
Moy Baun, and Brendan Paul, knowingly affected interstate or foreign commerce, or within
the special maritime and territorial jurisdiction of the United States, did knowingly and
intentionally conspire to violate Title 18, United States Code, Section 1962(c), that is, to
conduct and participate, directly and indirectly, in the conduct of the affairs of that enterprise
through a pattern of racketeering activity, as defined in Title 18, United States Code, Sections
1961(1) and 1961(5). In addition to violating federal law, these acts violated the following
state statutes: Florida, Penal Code 893.135; California, Health and Safety Code § 11352; New
York, Penal Codes 220.77, 220.18, 220.50, and 220.06; and USVI, Penal Code tit. 19, § 614a.
256. The Combs Rico Enterprise36: As detailed throughout this pleading, Defendants Sean
Combs, Love Records, Combs Enterprises, Justin Combs, Kristina Khorram, through her
36
“enterprise” includes any individual, partnership, corporation, association, or other legal entity, and any union or
group of individuals associated in fact although not a legal entity. 18 U.S.C.S. § 1961 (LexisNexis, Lexis Advance
through Public Law 118-40, approved March 1, 2024).
62
direct reports Frankie Santella, Moy Baun, and Brendan Paul, are an enterprise as the term is
defined pursuant to 18 USCS § 1961 (4). That is, a group of individuals associated, in fact,
that engaged in, and the activities of which affected interstate and foreign commerce. The
enterprise constituted an ongoing organization whose members functioned as a continuing
unit to achieve the enterprise's objectives.
257. Upon information and belief, the Combs Rico Enterprise is comprised of individuals
residing in and around Los Angeles, California, Miami, Florida, New York, New York, among
other places. Members and associates of the Combs Rico Enterprise have engaged in drug
trafficking and firearms trafficking.
258. Upon information and belief, members and associates of the Combs Rico Enterprise
procured, transported, and distributed ecstasy, cocaine, GHB, ketamine, marijuana,
mushrooms, and tuci in and around the States of New York, California, Florida, the USVI,
and elsewhere. During the relevant timeframe, through their general business partnership,
Defendants Lucian Charles Grainge, in his capacity as CEO of UMG, authorized Motown
Records and Universal Music Group to provide financial resources to Defendants Sean
Combs and Love Records. According to the Habtemariam Declaration, this financial support
was supposed to pay (or reimburse) Love Records for certain of the invoiced recording costs
incurred by Love Records in making The Love Album. According to Plaintiff Jones, while
the Combs Rico Enterprise was procuring, transporting, and distributing ecstasy, cocaine,
GHB, ketamine, marijuana, mushrooms, and tuci, it was during the making of The Love
Album.
259. The purpose of the Combs Enterprise: As detailed throughout this pleading, and
according to Plaintiff Jones, the purpose of the Combs Enterprise is to:
a. Use its position, power, and influence to control artists, creatives, musicians, and
producers to force these creatives to purchase, transport, and distribute illegal firearms
and drugs,
b. Promoting and enhancing the prestige, reputation, and position of the enterprise with
respect to rival music labels, artists and executives,
c. Preserving and protecting the power, territory, and criminal ventures of the enterprise
through the use of intimidation, threats of violence, and coercion,
d. Keeping victims in fear of the enterprise and its members and associates,
63
e. Enriching the members and associates of the enterprise through criminal activity,
including narcotics trafficking and fraud,
f. Concealing the activities of the enterprise from law enforcement by instructing the
associates of the enterprise to consult with Faheem Muhammed, the enterprise head
of security, if they ever encounter any problems with law enforcement.
260. Methods and Means of the Enterprise: Upon information and belief, among the means
and methods by which the defendants and their associates conducted and participated in the
conduct of the affairs of the enterprise were the following:
g. Members of the enterprise and their associates procured, transported and distributed
ecstasy, cocaine, GHB, ketamine, marijuana, mushrooms, and tuci by packing these
substances in their carry-on luggage and going through TSA. Plaintiff Jones
personally witnessed members of the enterprise do this during national and
international travel, as detailed below:
Enterprise Member Approximate Dates of Location: (Starting and
Travel destination)
DeForrest Taylor 11/22/2022 Los Angeles, California to

Miami, Florida
Brendan Paul 12/22/2022 Miami, Florida to Saint

Barthélemy37
Brendan Paul38, and 04/28/2023 Los Angeles – to New

Kristina Khorram York City – Virginia – to
Los Angeles
Brendan Paul39 11/4/2023 Los Angeles, California to
London England40
37
Mr. Jones is uncertain if it was a direct flight or if he stopped off in Los Angeles or New York prior to his arrival to
Saint Barthélemy.
38
Brendan and Kristina Khorram brought drugs. Plaintiff and the Combs Rico Enterprise were rehearsing for
“something in the water festival” in Virginia. Plaintiff Jones personally witness Mr. Combs do a few lines of coke in
his dressing room. Defendant Sean Combs wanted tuci but Brendan forgot it, so Defendant Kristina Khorram called
Yung Miami. Who then brought it on the private jet from Miami.
39
Packed cocaine in his carryon luggage in the garage of Defendant Combs house the evening of 11/3/2023.
40
Defendant Combs and Giggs reunited in London, England on November 7, 2023, for a sold-out show at O2
Shepherd’s Bush Empire. https://www.voice-online.co.uk/entertainment/music/2023/10/30/hip-hop-titans-giggs-
and-diddy-to-perform-special-one-night-only-event/
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261. According to Mr. Jones, the Combs Enterprise defendants informed the members and
associates of the enterprise that it would be safe to transport narcotics through in their carryon
luggage because according, to a TSA advisory, TSA security officers do not search for
marijuana or other illegal drugs41.
262. The following is a screenshot of a video taken on Mr. Combs' yacht on or about December
25, 2022, at 2:40 am; Brendan Paul is videotaped with one of the black pouches Defendant
Combs, and Kristina Khorram required the associates and members of the Combs Rico
Enterprise to carry. This pouch was filled with ecstasy, cocaine, GHB, ketamine, marijuana,
mushrooms, and tuc:
41
https://www.tsa.gov/travel/security-screening/whatcanibring/items/medical-
marijuana#:~:text=Accordingly%2C%20TSA%20security%20officers%20do,to%20a%20law%20enforcement%20
officer.
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263. The pattern of racketeering activity through which Defendants Sean Combs, Love Records,
Combs Enterprises, Justin Combs, Kristina Khorram, through her direct reports Frankie
Santella, Moy Baun, and Brendan Paul, together with others, agreed to conduct and participate
directly and indirectly, in the conduct of the affairs of the enterprise consisted of multiple
offenses involving dealing in controlled substances, in violation of Title 21, United States
Code, Sections 841, 843 and 846. It was part of the conspiracy that each defendant agreed
that a conspirator would commit at least two acts of racketeering activity in the conduct of the
affairs of the enterprise.
Defendants Committed Multiple Acts of Mail Fraud in Violation of 18 U.S.C. § 1341 in
264. Defendants voluntarily and intentionally devised and participated in a scheme to defraud
Plaintiffs out of money, relying on the mail. They committed these acts with the intent to
defraud Plaintiff Jones and the artists, creatives, musicians, and producers.
265. Defendants used the mail to execute the fraudulent scheme herein.
266. Specifically, the Defendants agreed to each of the acts of mail fraud described throughout
this Complaint. In addition, They agreed to rely on the mail to secure wire frauds and cash
payments from purchasers of the illegal firearms and drugs they required others to sell and
distribute.
267. In furtherance of and for purposes of executing the above-described fraudulent and illegal
course of conduct and scheme to defraud, Defendants, either individually or in combination
with themselves, used and caused to be used the U.S. mail by both placing and causing to be
placed cash, letters, marketing materials, advertisements, agreements and other matters in
depositories and by removing or causing to be removed letters and other mailable matters
from depositories, in violation of the mail fraud statute, 18 U.S.C. § 1341.
268. Defendants could not have furthered their fraud without the use of the mail. For example,
Defendants sought to acquire wire transfers and cash payments and to utilize their talents and
labor to produce music and other tangible goods and services without full compensation.
Defendants also required the mail to distribute misleading advertisements to various states,
including New York. For these reasons, the use of mail to conduct fraudulent activity was
necessary and inevitable.
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Defendants Committed Multiple Acts of Wire Fraud in Violation of 18 U.S.C. § 1343 in

269. Defendants voluntarily and intentionally devised and participated in a scheme to defraud
Plaintiff out of money, in reliance on the mail. Defendants committed these acts with the
intent to defraud Plaintiff Jones and the artists, creatives, musicians, and producers.
270. Specifically, Defendants agreed to each of the acts of wire fraud described throughout this
Complaint. In addition, Defendants agreed to rely on interstate wires to disseminate funds
and to submit payment to sex workers and prostitutes, as well as to transfer payment for the
distribution and procurement of drugs and guns. Defendants illegally acquired wire transfers,
money transfers, credit cards, and bank cards via search engines and other online platforms
to further their collective goal of furthering their RICO enterprise. Defendants knew that
these online purchases were illegally made.
271. Additionally, Defendants agreed that Defendants should facilitate these fraudulent
purchases over interstate wires in furtherance of the fraud. Sex workers and prostitutes
nationwide have received payment from Defendants.
272. In furtherance of and for purposes of executing the above-described fraudulent and illegal
course of conduct and scheme or artifice to defraud, Defendants, either individually or in
combination with themselves, used or caused to be used interstate wire communications to
transmit or disseminate false, fraudulent, and misleading communications and information, in
violation of the wire fraud statute, 18 U.S.C. § 1343..
273. Defendants could not have furthered their fraud without the ability to use
telecommunications to share information with clients and retailers nationwide. Because
Defendants needed to communicate with clients and retailers around the country, using
interstate telecommunications wires to conduct the fraudulent activity was necessary and
inevitable.
274. Plaintiffs have been damaged in their business or property because Defendants violated 18
U.S.C. § 1962(a), (c)-(d)), and, therefore, he is entitled to recover the damages and other
remedies enumerated therein..
275. Defendants’ acts or omissions were actuated by actual malice and a willful and wanton
disregard for the consequences suffered by Plaintiff and with knowledge of a high degree of
probability of harm to Plaintiff and reckless indifference to the consequences of their acts or
omissions.
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276. Compensatory damages alone will be insufficient to deter such conduct in the future. There
needs to be a criminal referral to the United States Justice Department, as well as to the States
Attorney General’s Office.
WHEREFORE, Plaintiff requests that the Court issue an Order and grant Judgment to the
Plaintiffs as follows:
a. Granting Plaintiff statutory, common law, and punitive damages, and applicable pre-
and post-judgment interest, in full recompense for damages;42
b. Entering judgment according to the declaratory relief sought;
c. Granting Plaintiff such other and further relief, including, without limitation,
injunctive and equitable relief, as the Court deems just in all the circumstances; and
d. Granting Plaintiff an Incentive or Service Award reflective of the work done in
prosecuting this action, the time spent, the effort and hard costs invested, and results
obtained, in light of the Court's judgment informed by awards in other similar cases
of comparable difficulty and complexity.
SECOND CAUSE OF ACTION

SEXUAL ASSAULT AND SEXUAL HARASSMENT
(against Mr. Combs)
forth fully herein.
278. As described above, Mr. Combs frightened and placed Plaintiff in apprehension of harm
when he physically and sexually assaulted him from October 2022 to October 2023 in Mr.
Combs' home in Miami, New York, the United States Virgin Islands, and Los Angeles.
279. Mr. Combs forcibly touched and attempted and/or threatened to touch Plaintiff's intimate
areas and/or touched Plaintiff with his own intimate body parts.
280. Mr. Combs violently gripped and palmed Mr. Jones' anus and crotch without consent. Mr.
Combs forced Mr. Jones to work in Mr. Combs' bathroom and watch Mr. Combs as he
showered. Mr. Combs forced Mr. Jones to work in the studio while Mr. Combs stripped naked
to get his body massaged. Mr. Combs forced Mr. Jones to work while Mr. Combs walked
around naked.
281. As a result of Mr. Combs' conduct, Plaintiff has suffered and continues to suffer harm,
including physical injury, severe emotional distress, humiliation, anxiety, and other
consequential damages for which he is entitled to an award of monetary damages and other
relief.
42
Damages shall include, but not be limited to, all damages permitted under the New Jersey Racketeer Influenced and
Corrupt Organizations Act.
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282. Mr. Combs' conduct described above was willful, wanton, and malicious. At all relevant
times, Mr. Combs acted with conscious disregard for Plaintiff's rights and feelings, acted with
the knowledge of or with reckless disregard for the fact that his conduct was sure to cause
injury and/or humiliation to Plaintiff, and intended to cause fear, physical injury and/or pain
and suffering to Plaintiff. By virtue of the foregoing, Plaintiff is entitled to recover punitive
damages.
THIRD CAUSE OF ACTION
SEXUAL ASSAULT
(against Jane Doe 1 (Yung Miami’s Cousin))
forth fully herein.
284. As described above, Jane Doe 1 frightened and placed Plaintiff in apprehension of harm
when she physically and sexually assaulted him on Thanksgiving Day, 2022, in Mr. Combs's
home in Miami, Florida.
285. Jane Doe 1 forcibly touched and attempted and/or threatened to touch Plaintiff's intimate
areas and/or touched Plaintiff with her own intimate body parts. Jane Doe 1 used her mouth
and performed oral sex on Plaintiff while he was urinating in the restroom. The Plaintiff
fought her off while Mr. Combs and his associates sat outside loudly laughing. Jane Doe 1
then followed Mr. Jones outside of the restroom and began undressing in front of Mr. Combs
and his associates, straddled Mr. Jones, and attempted to have forced sexual intercourse with
him.
286. As a result of Jane Doe 1's conduct, Plaintiff has suffered and continues to suffer harm,
including physical injury, severe emotional distress, humiliation, anxiety, and other
relief.
287. The conduct of Jane Doe 1 described above was willful, wanton, and malicious. At all
relevant times, Jane Doe 1 acted with conscious disregard for Plaintiff's rights and feelings,
acted with the knowledge of or with reckless disregard for the fact that her conduct was certain
to cause injury and/or humiliation to Plaintiff, and intended to cause fear, physical injury
and/or pain and suffering to Plaintiff. By virtue of the foregoing, Plaintiff is entitled to recover
punitive damages.
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FOURTH CAUSE OF ACTION

PREMISES LIABILITY FOR THE SEXUAL ASSAULT COMMITTED BY
JANE DOE 1 (YUNG MIAMI’S COUSIN)
(against Mr. Combs)
forth fully herein.
289. Mr. Jones was sexually assaulted by Jane Doe 1 in Miami, Florida, on Thanksgiving 2022.
Mr. Combs was present while Mr. Jones was being assaulted by Jane Doe 1. Mr. Jones was
legally on the premises as a guest and invitee of Mr. Combs. Jane Doe 1 was legally on the
premises as a guest and invitee of Mr. Combs. Mr. Combs owned the premises and had
dominion and control over the premises where Mr. Jones was harmed. Mr. Combs had
dominion and control over the actions of Jane Doe 1 and failed to step in and stop Jane Doe
1 from sexually assaulting Mr. Jones.
290. As the property owner, Mr. Combs had a duty to protect Mr. Jones from the harm he
suffered at the hands of Jane Doe 1. Mr. Combs breached his duty when he failed to stop Jane
Doe 1 from sexually assaulting Mr. Jones. In furtherance of this breach, Mr. Combs was
laughing and encouraging Jane Doe 1 to continue her assault on Mr. Jones. Mr. Jones has
suffered immensely because of Mr. Combs' intentional breach of his duty to him.
291. As a result of Mr. Combs's breach of his duty, Mr. Jones has suffered and continues to
suffer harm, including severe emotional distress, anxiety, and other consequential damages,
for which he is entitled to an award of monetary damages and other relief.
292. Mr. Combs's conduct described above was willful, wanton, and malicious. At all relevant
the knowledge of or with reckless disregard for the fact that their conduct was certain to cause
injury to Plaintiff, and intended to cause fear, physical injury and/or pain and suffering to
Plaintiff. By virtue of the foregoing, Plaintiff is entitled to recover punitive damages.
FIFTH CAUSE OF ACTION

PREMISES LIABILITY FOR THE SEXUAL ASSAULT COMMITTED
BY CUBA GOODING, JR.
(against, Mr. Combs)
forth fully herein.
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294. Here, Mr. Jones was sexually assaulted by Cuba Gooding Jr. on a yacht rented by Mr.
Combs in the US Virgin Islands in January 2023. Mr. Combs was present while Cuba
Gooding Jr. was assaulting Mr. Jones. Mr. Jones was legally on the premises as a guest and
invitee of Mr. Combs. Cuba Gooding Jr was legally on the premises as a guest and invitee of
Mr. Combs. Mr. Combs owned (through renting) the premises and had dominion and control
over the premises where Mr. Jones was harmed. Mr. Combs had dominion and control over
the actions of Cuba Gooding Jr and failed to step in and stop Cuba Gooding Jr from sexually
assaulting Mr. Jones.
295. As the owner of the property, Mr. Combs had a duty to protect Mr. Jones from the harm he
suffered at the hands of Cuba Gooding Jr. Mr. Combs breached his duty when he failed to
stop Cuba Gooding Jr from sexually assaulting Mr. Jones. In furtherance of this breach, Mr.
Combs encouraged Cuba Gooding Jr to continue his assault on Mr. Jones when he said that
Cuba Gooding Jr should privately get to know Mr. Jones better. Mr. Jones has suffered
immensely because of Mr. Combs's intentional breach of his duty to him.
296. As a result of Mr. Combs' breach of his duty, Mr. Jones has suffered and continues to suffer
harm, including severe emotional distress, anxiety, and other consequential damages, for
which he is entitled to an award of monetary damages and other relief.
297. Mr. Combs' conduct described above was willful, wanton, and malicious. At all relevant
the knowledge of or with reckless disregard for the fact that his conduct was certain to cause
injury to Plaintiff, and intended to cause fear, physical injury and/or pain and suffering to
Plaintiff. By virtue of the foregoing, Plaintiff is entitled to recover punitive damages.
SIXTH CAUSE OF ACTION

TRAFFICKING AND VICTIMS’ PROTECTION ACT
(against, Defendants Sean Combs, Justin Combs, Kristina Khorram, And
Combs Global)
forth fully herein.
299. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global knowingly
and intentionally participated in, perpetrated, assisted, supported, and facilitated a sex-
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trafficking venture that was in and affecting interstate and foreign commerce, together and
with others, in violation of 18 U.S.C. § 1591(a)(1).
300. Among other things, Defendants Sean Combs, Justin Combs, Kristina Khorram, and
Combs Global knowingly and intentionally recruited, enticed, provided, obtained, advertised,
and solicited by various means Mr. Jones, as well as other Class Members, knowing that
Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global would use
means of force, threats of force, fraud, coercion, and a combination of such means to cause
Mr. Jones, as well as others, some of whom were under the age of seventeen, to engage in
commercial sex acts.
301. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global and its
employees had actual knowledge that they were perpetrating and facilitating Mr. Combs’
sexual abuse and sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport,
obtain, and provide Mr. Jones as well as others who were under the age of seventeen, into
commercial sex acts, through the means of force, threats of force, fraud, abuse of process, and
coercion.
302. Despite such knowledge, Defendants Sean Combs, Justin Combs, Kristina Khorram, and
Combs Global intentionally paid for, facilitated, perpetrated, and participated in Mr. Combs’
violations of 18 U.S.C. § 1591(a)(1), which Defendants Sean Combs, Justin Combs, Kristina
Khorram, and Combs Global knew, and were in reckless disregard of the fact that Mr. Combs
would coerce, defraud, and force Mr. Jones to engage in commercial sex acts.
303. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global’s actions
were in and affecting interstate and foreign commerce, including its music distributing and
publishing activities which were in and affecting interstate and foreign commerce.
304. By taking the concrete steps alleged in this complaint, Defendants Sean Combs, Justin
Combs, Kristina Khorram, and Combs Global knowingly participated in sex trafficking and
furthered the Combs’ sex-trafficking venture. The concrete steps constituted taking part in
the sex-trafficking venture and were necessary for its success. The concrete steps constituted
active engagement by Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs
Global in Mr. Combs’s sex-trafficking venture. Defendants Sean Combs, Justin Combs,
Kristina Khorram, and Combs Global knew that its active engagement would lead to and
cause coercive commercial sex trafficking.
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305. As part of perpetrating TVPA violations, between on or about September 12, 2022, and
through about November 2023, Defendants Sean Combs, Justin Combs, Kristina Khorram,
and Combs Global concealed its delivery of hundreds of thousands of dollars in cash to Mr.
Combs and his associates.
306. In addition to perpetrating TVPA violations, Defendants Sean Combs, Justin Combs,
Kristina Khorram, and Combs Global willfully failed to file required taxes with the federal
government.
307. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global’s
affirmative conduct was committed knowing, and in reckless disregard of the facts, that Mr.
Combs would use cash and the financial support provided by Defendants Love Records,
Motown Records, and the Universal Music Group as a means of defrauding, forcing, and
coercing sex acts from Plaintiff Jones as well as others. Defendants Sean Combs, Justin
Combs, Kristina Khorram, and Combs Global’s conduct was outrageous and intentional. On
or about January 2023, Justin Combs engaged in a freak-off session on a yacht with his father
and sex workers.
308. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global’s knowing
and intentional conduct has caused Mr. Jones serious harm, including, without limitation,
physical, psychological, emotional, financial, and reputational harm.
309. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global’s knowing
and intentional conduct has caused Mr. Jones harm that is sufficiently serious, under all the
surrounding circumstances, to compel a reasonable person of the same background and in the
same circumstances to perform or to continue performing commercial sexual activity, to avoid
incurring that harm.
310. This case does not involve mere fraud. Instead, Defendants Sean Combs, Justin Combs,
Kristina Khorram, and Combs Global’s criminal conduct in perpetrating TVPA violations
was outrageous and intentional because it was in deliberate furtherance of a widespread and
dangerous criminal sex trafficking organization. Defendants Sean Combs, Justin Combs,
Kristina Khorram, and Combs Global’s criminal conduct also evinced a high degree of moral
turpitude and demonstrated such wanton dishonesty as to imply a criminal indifference to
civil obligations. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs
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Global’s criminal conduct was directed specifically at Mr. Jones, who was the victim of Mr.
Combs’ sexual abuse and sex trafficking harassment.
311. Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global’s
outrageous and intentional conduct in this case is part of a pattern and practice of profiting by
undertaking illegal “high risk, high reward” actions.
312. By virtue of these knowing and intentional violations of 18 U.S.C. §§ 1591(a)(1), 1595,
Defendants Sean Combs, Justin Combs, Kristina Khorram, and Combs Global are liable to
Mr. Jones for the damages they sustained, and reasonable attorneys’ fees.
313. By virtue of these intentional and outrageous violations of 18 U.S.C. § 1591(a)(1), 1595,
Defendants Sean Combs, Justin Combs, and Kristina Khorram are liable to Mr. Jones.
SEVENTH CAUSE OF ACTION

AIDING, ABETTING, AND INDUCING A SEX-TRAFFICKING VENTURE IN
VIOLATION OF THE TRAFFICKING VICTIMS’
PROTECTION ACT, 18 U.S.C. §§ 2, 1591(a)(1) & (2), 1595
(against Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Group)
forth fully herein.
315. Defendants Lucian Charles Grainge in his capacity as CEO of UMG, authorized Motown
Records, and Universal Music Group to enter into a general partnership agreement with Sean
Combs and Love Records. As general business partners each individual member is
responsible for the actions of the partners of the partnership. Defendants Lucian Charles
Grainge in his capacity as CEO of UMG, authorized Motown Records, and Universal Music
Group to provide financing to Sean Combs, and Love Records, Inc. According to the
Habtemariam Declaration this financial support was supposed to pay (or reimburse) Love
Records for certain of the invoiced recording costs incurred by Love Records in making The
Love Album. According to Plaintiff Jones, while the Combs Rico Enterprise was engaging
in sex trafficking activities it was during the making of The Love Album. Upon information
and belief, Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown
Records, and Universal Music Group did not implement any mechanism to monitor how the
Mr. Combs and Love Records, Inc. was spending the money. As a result of their intentional
or negligent failure of their duty to supervise, Defendants Lucian Charles Grainge in his
74
capacity as CEO of UMG, Motown Records, and Universal Music Group aided, abetted, and
induced Sean Combs’ sex-trafficking venture that was in and affecting interstate and foreign
commerce, together and with others, in violation of 18 U.S.C. §§ 2, 1591(a)(1) & (a)(2).
316. The crimes that Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Group aided and abetted are (1) Mr. Combs’s
perpetrating of coercive sex trafficking, in violation of 18 U.S.C. § 1591(a)(1), and (2) Mr.
Combs’ co-conspirators knowingly benefitting from coercive sex trafficking, in violation of
18 U.S.C. § 1591(a)(2). These crimes were in and affecting interstate and foreign commerce.
317. Mr. Combs’ co-conspirators benefitted financially and received things of value from their
participation in the Combs sex-trafficking venture, including payments and other
compensation from Mr. Combs. The co-conspirators who benefitted financially include
Defendants J. Combs, Khorram and her direct reports: Brendan Paul, Frankie Santella, and
Moy Baun.
318. Under 18 U.S.C. § 2, as a result of their general business partnership with Defendant Sean
Combs, and Love Records, Inc., and their failure to monitor their financing of Defendants
Sean Combs and Love Records, Defendants Lucian Charles Grainge in his capacity as CEO
of UMG, Motown Records, and Universal Music Group are punishable as a principal under
18 U.S.C. §§ 1591(a)(1) & (a)(2) and thereby committed and perpetrated violations of Chapter
77, Title 18, U.S. Code, when it aided, abetted, counseled, commanded, induced, and procured
Combs’ and his co-conspirators sex-trafficking venture and sex trafficking of Plaintiff Jones,
as well as others.
319. Under 18 U.S.C. § 2, as a result of their general business partnership with Defendant Sean
Combs, and Love Records, Inc., and their failure to monitor their financing of Defendants
Sean Combs and Love Records, Defendants Lucian Charles Grainge in his capacity as CEO
of UMG, Motown Records, and Universal Music Group committed and perpetrated crimes in
violation of 18 U.S.C. §§ 1591(a)(1) & (a)(2) by aiding, abetting, inducing, and procuring
Combs’ and his co-conspirator’s sex-trafficking venture and the sex trafficking of Mr. Jones.
As a consequence, Mr. Jones is a victim of Defendants J. Combs, Khorram and her direct
reports: Brendan Paul, Frankie Santella, and Moy Baun’s criminally aided, abetted, and
inducing Combs’ and his co-conspirators’ violations of 18 U.S.C. §§ 1591(a)(1) & (a)(2).
75
320. Defendants J. Combs, Khorram and her direct reports: Brendan Paul, Frankie Santella, and
Moy Baun itself directly committed and perpetrated violations of Chapter 77, Title 18, U.S.
Code, including 18 U.S.C. §§ 1591(a)(1) & (a)(2), by aiding, abetting, and inducing the sex-
trafficking venture and the sex trafficking of Plaintiff Jones. Defendants J. Combs, Khorram
and her direct reports: Brendan Paul, Frankie Santella, and Moy Baun themselves directly
violated Chapter 77 by committing and perpetrating these violations.
321. Among other things, Defendants J. Combs, Khorram and her direct reports: Brendan Paul,
Frankie Santella, and Moy Baun aided, abetted, and induced Combs’ and his co-conspirators’
sex-trafficking venture and sex trafficking of Plaintiff Jones knowing that Combs and his-
conspirators would use means of force, threats of force, fraud, coercion, and a combination of
such means to cause Mr. Jones to engage in commercial sex acts.
322. By aiding, abetting, and inducing Mr. Combs’ and his co-conspirators’ sex-trafficking
venture and sex trafficking of Plaintiff. Defendants J. Combs, Khorram and her direct reports:
Brendan Paul, Frankie Santella, and Moy Baun benefited, both financially and by receiving
things of value, from participating in Combs’ sex-trafficking venture.
323. Defendants J. Combs, Khorram and her direct reports: Brendan Paul, Frankie Santella, and
Moy Baun and its employees had actual knowledge that they were aiding, abetting, and
inducing Combs’ and his co-conspirators’ sexual abuse and sex trafficking conspiracy to
recruit, solicit, entice, coerce, harbor, transport, obtain, and provide Mr. Jones as well as
others, into commercial sex acts, through the means of force, threats of force, fraud, abuse of
process, and coercion. Defendants knew, and should have known, that Mr. Combs had
engaged in acts in violation of the TVPA.
324. Despite such knowledge, and through their intentional or negligent failure to monitor how
their financial support of Mr. Combs and Love Records was being spent, Defendants Lucian
Charles Grainge in his capacity as CEO of UMG, Motown Records, and Universal Music
Group financed and aided, abetted, and induced Combs’ violations of 18 U.S.C. §§ 1591(a)(1)
& (a)(2), which constituted perpetrating violations of those laws under 18 U.S.C. § 2.
Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown Records, and
Universal Music Group knew or should have known if they had conducted a simple
investigation, and acted in reckless disregard of the fact that, Combs would coerce, defraud,
and force Mr. Jones to engage in commercial sex acts.
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325. Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown Records,
and Universal Music Group’s affirmative conduct of blindly financing Defendant Combs and
Love Records, Inc. aided, abetted, and induced Combs’. Their violations were committed
knowingly, and in reckless disregard of the facts, that Mr. Combs would use the financial
support provided by Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Group as a means of defrauding, forcing, and coercing
sex acts from Mr. Jones. Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Groups conduct was outrageous and intentional.
326. Upon information and belief, Defendants Lucian Charles Grainge in his capacity as CEO
of UMG, Motown Records, and Universal Music Group’s knowing and intentional conduct
of aiding, abetting, and inducing Combs’s violations has caused Mr. Jones serious harm
including, without limitation, physical, psychological, emotional, financial, and reputational
harm.
327. Through their unchecked financial support Defendants Sean Combs, and Love Records,
Inc., Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown Records,
and Universal Music Group’s aided, abetted, and induced Combs’s violations and caused Mr.
Jones harm that is sufficiently serious, under all the surrounding circumstances, to compel a
reasonable person of the same background and in the same circumstances to perform or to
continue performing commercial sexual activity, in order to avoid incurring that harm.
328. This case does not involve mere fraud. Instead, Defendants’ criminal conduct in aiding,
abetting, and inducing Combs’s violations of the TVPA was outrageous and intentional,
because it was in deliberate furtherance of a widespread and dangerous criminal sex
trafficking organization. Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Group’s criminal conduct also evinced a high degree
of moral turpitude and demonstrated such wanton dishonesty as to imply a criminal
indifference to civil obligations. Defendants Lucian Charles Grainge in his capacity as CEO
of UMG, Motown Records, and Universal Music Group’s criminal conduct was directed
specifically at Mr. Jones, who was the victim of Mr. Combs’s sexual abuse and sex trafficking
organization.
and Universal Music Group’s outrageous and intentional conduct in this case is part of a
77
pattern and practice of Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Group profiting by undertaking illegal “high risk, high
reward” general business partnerships.
Universal Music Group are liable to Mr. Jones for the damages he sustained and reasonable
attorneys’ fees.
331. By virtue of these intentional and outrageous violations of 18 U.S.C. §§ 1591(a)(1), 1595,
Universal Music Group are liable to Mr. Jones for punitive damages.
EIGHT CAUSE OF ACTION

NIED (FOR SEXUAL ASSAULT)
(against Defendant Jane Doe 1 (Yung Miami’s Cousin))
forth fully herein.
333. Jane Doe 1’s conduct created an unreasonable risk of causing emotional distress to Plaintiff,
and Jane Doe 1 knew or should have known that such conduct was likely to result in emotional
distress that might and/or likely would cause illness or bodily harm.
334. The Plaintiff’s emotional distress was foreseeable to Jane Doe 1.
335. As a direct and proximate result of the negligent conduct of Jane Doe 1, Plaintiff suffered
and will continue to suffer severe emotional distress.
336. Jane Doe 1’s conduct was wanton, malicious, willful, and/or cruel, entitling the Plaintiff to
punitive damages.
NINTH CAUSE OF ACTION

(against Mr. Combs)
forth fully herein.
338. Mr. Combs’ conduct created an unreasonable risk of causing emotional distress to Plaintiff,
and Plaintiff knew or should have known that such conduct was likely to result in emotional
distress that might and/or would likely cause illness or bodily harm.
339. The Plaintiff’s emotional distress was foreseeable to Mr. Combs.
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340. As a direct and proximate result of the negligent conduct of Mr. Combs, Plaintiff suffered
and will continue to suffer severe emotional distress.
341. Mr. Combs’ conduct was wanton, malicious, willful, and/or cruel, entitling the Plaintiff to
punitive damages.
TENTH CAUSE OF ACTION
IIED (FOR SEXUAL ASSAULT)
Defendant Jane Doe 1 (Yung Miami’s Cousin)
forth fully herein.
343. Jane Doe 1 engaged in conduct toward Plaintiff that is extreme and outrageous to exceed
the bounds of decency in a civilized society, namely by, inter alia, subjecting him to sexual
assault and misconduct.
344. The sexual assault and misconduct by Jane Doe 1 were extreme and outrageous conduct
that shocks the conscience.
345. These actions were taken with the intent to cause or disregard for the substantial probability
of causing severe emotional distress.
346. As a direct and proximate result of Jane Doe 1’s extreme and outrageous conduct, Plaintiff
has suffered severe emotional distress.
347. The Defendant's conduct was wanton, malicious, willful, and/or cruel, entitling the Plaintiff
to punitive damages.
ELEVENTH CAUSE OF ACTION

(against Mr. Combs)
forth fully herein.
349. Mr. Combs engaged in conduct toward Plaintiff that is extreme and outrageous to exceed
the bounds of decency in a civilized society, namely by, inter alia, subjecting him to sexual
assault and misconduct.
350. The sexual assault and misconduct by Mr. Combs were extreme and outrageous conduct
that shocks the conscience.
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352. As a direct and proximate result of Mr. Combs’ extreme and outrageous conduct, Plaintiff
has suffered severe emotional distress.
TWELFTH CAUSE OF ACTION
(against Mr. Gooding, Jr.)
forth fully herein.
355. Mr. Gooding, Jr. engaged in conduct toward Plaintiff that is extreme and outrageous to
exceed the bounds of decency in a civilized society, namely by, inter alia, subjecting him to
sexual assault and misconduct.
356. The sexual assault and misconduct by Mr. Gooding, Jr. were extreme and outrageous
conduct that shocks the conscience.
358. As a direct and proximate result of Mr. Gooding, Jrs’ extreme and outrageous conduct,
Plaintiff has suffered severe emotional distress.
THIRTEENTH CAUSE OF ACTION
forth fully herein.
361. Mr. Gooding, Jrs’ conduct created an unreasonable risk of causing emotional distress to
Plaintiff, and Plaintiff knew or should have known that such conduct was likely to result in
emotional distress that might and/or would likely cause illness or bodily harm.
362. The Plaintiff’s emotional distress was foreseeable to Mr. Gooding, Jr.
363. As a direct and proximate result of the negligent conduct of Mr. Gooding, Jr., Plaintiff
suffered and will continue to suffer severe emotional distress.
364. Mr. Gooding, Jr.s’ conduct was wanton, malicious, willful, and/or cruel, entitling the
Plaintiff to punitive damages.
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FOURTEENTH CAUSE OF ACTION

SEXUAL ASSAULT
forth fully herein.
366. As described above, Mr. Gooding, Jr. frightened and placed Plaintiff in apprehension of
harm when he physically and sexually assaulted him on a yacht chartered by Mr. Combs in
the USVI.
367. Mr. Gooding, Jr. forcibly touched and attempted and/or threatened to touch Plaintiff's
intimate areas and/or touched Plaintiff with his own intimate body parts. Mr. Gooding, Jr.
used his hand and forcibly touched Plaintiff while he was in sitting on the yacht. The Plaintiff
pushed him off while Mr. Combs failed to intervene.
368. As a result of Mr. Gooding, Jr.'s conduct, Plaintiff has suffered and continues to suffer
harm, including physical injury, severe emotional distress, humiliation, anxiety, and other
relief.
369. The conduct of Mr. Gooding, Jr. described above was willful, wanton, and malicious. At
all relevant times, Mr. Gooding, Jr. acted with conscious disregard for Plaintiff's rights and
feelings, acted with the knowledge of or with reckless disregard for the fact that his conduct
was certain to cause injury and/or humiliation to Plaintiff, and intended to cause fear, physical
injury and/or pain and suffering to Plaintiff. By virtue of the foregoing, Plaintiff is entitled to
recover punitive damages.
FIFTEENTH CAUSE OF ACTION

KNOWING BENEFICIARY IN A SEX-TRAFFICKING VENTURE IN VIOLATION OF
THE TRAFFICKING VICTIMS’ PROTECTION ACT, 18 U.S.C. §§ 1591(A)(2), 1595
(against Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown
Records, and Universal Music Group)
forth fully herein.
371. Upon information and belief, through their general business partnership with Defendants
Sean Combs and Love Records, Inc., and their financing of the establishment of Love Records
and the Love Album, Defendants Lucian Charles Grainge, in his capacity as CEO of UMG,
Motown Records, and Universal Music Group knowingly and intentionally benefitted,
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financially and by receiving things of value, from participating in, assisting, supporting, and
facilitating an illegal coercive sex-trafficking venture that was in and affecting interstate and
foreign commerce, together and with others, in violation of 18 U.S.C. § 1591(a)(2)Defendant
Lucian Charles Grainge, in his capacity as CEO of UMG, Motown Records, and Universal
Music Group, took many concrete steps to aid and participate in Mr. Combs' sex-trafficking
venture. Among the concrete steps that Defendant Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, took to aid Mr. Combs was
providing unfettered access to financing, which made the sex-trafficking venture possible.
Providing Mr. Combs with large sums of U.S. currency caused Defendant Lucian Charles
Grainge, in his capacity as CEO of UMG, Motown Records, and Universal Music Group, to
receive the benefits detailed throughout this pleading. Defendant Lucian Charles Grainge, in
his capacity as CEO of UMG, Motown Records, and Universal Music Groups, willingness to
provide large sums of unchecked financing to Mr. Combs was the quid pro quo for it receiving
the benefits detailed within this pleading from Mr. Combs.
372. Upon information and belief, the financing that Defendant Lucian Charles Grainge, in his
capacity as CEO of UMG, Motown Records, and Universal Music Group, provided was
necessary for Mr. Combs to coerce Plaintiff Jones to engage in commercial sex acts. The
financing directly formed part of the commercial nature of the sex acts. The financing was
also a necessary and required part of Mr. Combs' recruitment of Plaintiff Jones, as well as
other sex workers. By providing unchecked financing, Defendant Lucian Charles Grainge, in
his capacity as CEO of UMG, Motown Records, and Universal Music Group, knew or should
have known that the money would be used to fund the sex trafficking venture. Through their
general business partnership with Defendants Sean Combs and Love Records, Inc.,
Universal Music Group, actively participated in the recruitment of victims of the venture.
373. Upon information and belief, the unchecked financing that Defendant Lucian Charles
Grainge, in his capacity as CEO of UMG, Motown Records, and Universal Music Group,
provided went far beyond providing routine partnership or compensation to a general business
partner. It was far from routine for Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, to provide substantial financing
throughout the years to Mr. Combs, who did not have an apparent legitimate need for such
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extravagant sums. The sheer number of "listening parties," yacht parties, and nighttime
writers camp after parties, which Defendants Lucian Charles Grainge, in his capacity as CEO
of UMG, Motown Records, and Universal Music Group, either intentionally or
unintentionally funded, went far beyond normal for the music industry. Defendants Lucian
Charles Grainge, in his capacity as CEO of UMG, Motown Records, and Universal Music
Group, knew or should have known through reasonable inquiry that they were feeding Mr.
Combs sexual deviancy. Moreover, the circumstances in which Mr. Combs requested such
large amounts were far from routine and should have raised numerous "red flags"—taking it
well outside routine circumstances.
374. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as CEO
of UMG, Motown Records, and Universal Music Group, provided large sums of financing to
Mr. Combs, which, under the circumstances of this case, was entirely inconsistent with the
ordinary duties of a record label, music group, publishing partner, or general business
partnership member.
375. Upon information and belief, the reason that Defendants Lucian Charles Grainge, in his
capacity as CEO of UMG, Motown Records, and Universal Music Group, ignored the
numerous red flags about Mr. Combs was to receive financial benefits from Mr. Combs and
his sex-trafficking venture. Defendants Lucian Charles Grainge, in his capacity as CEO of
UMG, Motown Records, and Universal Music Group, knew that it would gain far-from-
routine financial benefits by ignoring the red flags associated with Mr. Combs and by
participating in his sex- trafficking venture.
a. Upon information and belief, among the concrete steps that Defendants Lucian
Charles Grainge in his capacity as CEO of UMG, Motown Records, and Universal
Music Group took to aid and participate in the Combs sex-trafficking venture were
opening up numerous lines of finance for Mr. Combs's production of the Love Album.
By opening these unchecked lines of finance, Defendants Lucian Charles Grainge, in
his capacity as CEO of UMG, Motown Records, and Universal Music Group, received
many benefits from participating in Mr. Combs's venture. Through their general
business partnership agreement with Defendant Sean Combs and Love Records, Inc.,
they adopted by association the intentional acts of their general business partner, Sean
Combs, and Love Records, Inc.'s affirmative conduct that caused Defendants Lucian
Music Group to receive those benefits.
b. Upon information and belief, among the concrete steps that Defendants Lucian
Charles Grainge, in his capacity as CEO of UMG, Motown Records, and Universal
Music Group, took to aid the Combs sex- trafficking venture between about 2003 -
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2005, 2009-2015, and 2022 and continuing through about November 2023,
Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown
Records, and Universal Music Group concealed its delivery of vast sums financing
(likely millions of dollars) to Mr. Combs and his associates. To benefit from the
Combs sex-trafficking venture, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, willfully failed to do
their due diligence and ensure that their general business partners, Defendants Sean
Combs and Love Records, Inc. accurately accounted for all of the financing that they
received as it relates to the establishment of Love Records, Inc., and distribution of
Love Album by timely filing required tax disclosures surrounding the funding of these
sex trafficking parties with the federal government, because doing so would imperil
its ability to profit from the sex-trafficking venture. Due to their status as a general
business partner of Defendant Combs and Love Records, Inc., Defendants Lucian
Music Group, were equally liable for the concealment of the financial transactions
caused it to receive financial benefits through the continuation of the Combs sex-
trafficking venture.
c. Upon information and belief, among the concrete steps that Defendants Lucian
Charles Grainge took in his capacity as CEO of UMG, Motown Records, and
Universal Music Group took to aid the Combs sex- trafficking venture was its failure
to ensure that their general business partners Sean Combs and Love Records, Inc.
followed AML requirements. This failure was not just passive facilitation but a
deliberate omission by Defendants Lucian Charles Grainge in his capacity as CEO of
UMG, Motown Records, and Universal Music Group. This omission was a specific
act of concealment, which allowed Combs to continue funding his sex-trafficking
venture through suspicious transactions that would have otherwise been prevented.
Combs paid for his sex workers through cash payments or wire transfers.
d. Upon information and belief, by taking the concrete steps outlined above (along with
the others alleged in this complaint), Defendants Lucian Charles Grainge, in his
capacity as CEO of UMG, Motown Records, and Universal Music Group, knowingly
participated in sex trafficking and furthered the Combs sex-trafficking venture. The
concrete steps above constituted taking part in the sex-trafficking venture and were
necessary for its success. The concrete steps above constituted active engagement by
Records, and Universal Music Group in Combs's sex- trafficking venture.
e. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, knowingly and
intentionally benefited financially from, and received value for, its participation in the
sex-trafficking venture, in which Mr. Combs, with Defendants Lucian Charles
Grainge in his capacity as CEO of UMG, Motown Records, and Universal Music
Group's knowledge, or their reckless disregard of the fact, that Combs would use
means of force, threats of force, fraud, coercion, and a combination of such means to
cause Plaintiff Jones, as well as others, some of whom were under the age of
seventeen, to engage in commercial sex acts.
f. Upon information and belief, Defendants Lucian Charles Grainge in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, knew, through years of
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lawsuits, hush money settlements, and notice that was provided by Ms. Cassie Venture
at the beginning of 2023, that Mr. Combs was engaging in sex trafficking, and that
Records, and Universal Music Group was participating in a particular sex-trafficking
venture—i.e., the coercive Combs sex-trafficking venture outlined above through their
general business partnership deal with Defendants Sean Combs and Love Records,
Inc. Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown
Records, and Universal Music Group's knowledge went far beyond having an abstract
awareness of sex trafficking in general. Indeed, Defendants Lucian Charles Grainge
in his capacity as CEO of UMG, Motown Records, and Universal Music Group's
representatives, were present at Chalice Recording Studios and in Mr. Combs' Miami
and Los Angeles homes while he was actively engaging in acts enumerated in this
pleading, and the large sum of financing that Defendants Lucian Charles Grainge in
his capacity as CEO of UMG, Motown Records, and Universal Music Group gave him
access to. Thus, Defendants Lucian Charles Grainge, in his capacity as CEO of UMG,
Motown Records, and Universal Music Group, did not simply fail to adequately detect
signs of Combs' sex trafficking; it did detect multiple signs of Combs' coercive sex-
trafficking venture and continued to participate in the venture. Defendants Lucian
Music Group, knew or should have known that the venture was ongoing, which was
why Combs required vast sums of financing.
g. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group's actions, extend well
beyond a situation of failing to train themselves and their staff about recognizing the
warning signs of sex trafficking. Defendants Lucian Charles Grainge, in his capacity
as CEO of UMG, Motown Records, and Universal Music Group's employees, did
recognize the signs of Combs' sex trafficking. Upon information and belief, indeed,
Defendants Lucian Charles Grainge, in his capacity as CEO of UMG, Motown
Records, and Universal Music Group's employees, knew about Combs' sex-trafficking
venture. But Defendants Lucian Charles Grainge, in his capacity as CEO of UMG,
Motown Records, and Universal Music Group, decided to continue facilitating the
Combs sex-trafficking venture rather than ending its participation in the venture.
h. Upon information and belief, among the signs that Defendants Lucian Charles
Grainge, in his capacity as CEO of UMG, Motown Records, and Universal Music
Group, was facilitating Combs sex trafficking venture were those facts that came to
the attention of Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Group from the reporting of Cassie Ventura
mentioned above.
i. Upon information and belief, among the signs that Defendants Lucian Charles
Group, was facilitating Combs' sex trafficking venture were those facts that came to
the attention of Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Group were those facts that came to its
attention through complaints filed by Cassie Ventura of Combs' sex trafficking.
Because of those complaints, Defendants Lucian Charles Grainge, in his capacity as
85
CEO of UMG, Motown Records, and Universal Music Group — knew to a certainty
that Combs was engaged in sex trafficking.
j. Upon information and belief, Defendants Lucian Charles Grainge in his capacity as
CEO of UMG, Motown Records, and Universal Music Group and knew the names of
many of Combs' sex trafficking/freak-off participants (Yung Miami, Daphne Joy,
Stevie J, and Jade).
k. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, helped to conceal the
names of Combs' victims from the public and from law enforcement and prosecuting
agencies by helping to conceal the existence of the sex-trafficking venture. Among
the ways in which Defendants Lucian Charles Grainge, in his capacity as CEO of
UMG, Motown Records, and Universal Music Group, helped to conceal the venture's
existence was by failing to properly monitor or audit Sean Combs and Love Records,
Inc. to ensure that the finances they provided were being used in the manner outlined
in the Habtemariam Declaration, as well as ensuring that the proper accounting and
tax reporting was made to the federal government. Additionally, they knew or should
have known that Defendant Combs employed and empowered Faheem Muhammad to
handle law enforcement and Defendant Khorram to compensate the sex workers.
l. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group's concealment included
failing to provide enhanced monitoring that is normally required in general business
partnership agreements where one partner was providing the financing for the
partnership. Defendants Lucian Charles Grainge, in his capacity as CEO of UMG,
Motown Records, and Universal Music Group, failed to implement enhanced
monitoring of Mr. Combs to ensure that the finances they provided were being used
for the purpose identified in Ms. Habtemariams's Declaration. Upon information and
belief, they failed to do this specifically to help conceal Combs' ongoing sex
trafficking. Defendants Lucian Charles Grainge, in his capacity as CEO of UMG,
Motown Records, and Universal Music Group, knew that if it implemented that
enhanced monitoring, it would have to stop providing Combs with the financing he
needed to run his sex-trafficking venture.
m. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group's concealment included
failing to ensure that their general business partners, Sean Combs and Love Records,
Inc. properly reported their financial support of Mr. Combs to the federal government
for tax purposes. This includes reporting all payments or wire transfers sent to Caresha
Romeka Brownlee, Jade Ramey, and Daphne Joy Cervantes Narvaez.
n. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, had constructive
knowledge of Combs' sex-trafficking venture because of specific acts by Mr. Combs
that put it on notice of a particular and ongoing sex trafficking venture. Among the
specific acts were Combs' use of vast sums of financing and the club love parties that
representatives of UMG periodically attended; Defendant Combs had drugs and sex
workers present in circumstances that should have prompted Defendants Lucian
Music Group and its employees to raise questions about Combs's sex-trafficking, and
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or his use of the financing provided to him by Defendants Lucian Charles Grainge in
his capacity as CEO of UMG, Motown Records, and Universal Music Group.
o. Also, among the specific acts giving rise to constructive knowledge were the facts that
associates of Mr. Combs made numerous reimbursement requests to Defendants
Lucian Charles Grainge in his capacity as CEO of UMG, Motown Records, and
Universal Music Group through Mr. Combs' accountant Robin Greenhill. The
circumstances of these reimbursement requests gave Defendants notice that Mr.
Combs' sex-trafficking enterprise was being funded.
p. Upon information and belief, among the financial benefits that the Defendants Lucian
Music Group received for participating in and facilitating Combs' sex-trafficking
venture were the affiliation and access to Mr. Combs' popularity. Before Cassie
Ventura's lawsuit was filed, Mr. Combs was a popular and highly influential figure in
the music industry to whom everyone wanted to connect. Mr. Combs was known for
throwing the "best" parties. Affiliation with and/or general business partnerships with
Mr. Combs garnered legitimacy, immense success, and access to top and emerging
artists, celebrities, famous athletes, political figures, musicians, and international
dignitaries like British Royal and Prince Harry. Defendants Lucian Charles Grainge,
in his capacity as CEO of UMG, Motown Records, and Universal Music Group, knew
first-hand the power, influence, and effect attaching themselves to Mr. Combs would
have on their bottom-line and, as evidenced by their repeated general business
partnership agreements with Mr. Combs from 2003-2005, 2009-2015, and 2022-2023.
Defendants Lucian Charles Grainge, in his capacity as CEO of UMG, Motown
Records, and Universal Music Group, profited from their affiliation with Mr. Combs
and their general business partnership, which came with unmonitored financing that
may have supported his sex-trafficking enterprise. Mr. Combs and Combs-controlled
entities used the financing they received from their general business partners to
facilitate their sex trafficking venture. Mr. Combs benefited from his general business
partners' apparent willful blindness through their willingness to provide large amounts
of financing in suspicious circumstances and their failure to ensure that their general
business partners properly reported their financing to the U.S. Federal Government.
q. Upon information and belief, among the financial benefits that D Defendants Lucian
Music Group received for participating in Combs' sex-trafficking venture was the
referral of business opportunities from Mr. Combs and his co-conspirators. Access to
up-and-coming artists, producers, songwriters, and creatives. Defendants Lucian
Music Group, profited from these referred business opportunities. Mr. Combs referred
business opportunities to Defendants Lucian Charles Grainge in his capacity as CEO
of UMG, Motown Records, and Universal Music Group in exchange for financing his
sex trafficking venture. These referrals were a quid pro quo for Defendants Lucian
Music Group's unchecked financing of the establishment of Love Records, Inc., and
the funding and reimbursement for the invoiced expenses associated with the creation
of the Love Album.
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r. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, knowingly received
financial benefits in return for its assistance, support, and facilitation of Combs' sex-
trafficking venture. Defendants Lucian Charles Grainge, in his capacity as CEO of
UMG, Motown Records, and Universal Music Group, knew or should have known
that if it stopped assisting, supporting, and facilitating Combs' sex-trafficking venture,
it would no longer receive those benefits.
s. Upon information and belief, Defendants Lucian Charles Grainge in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, knew and was in
reckless disregard of the fact that it was Combs's pattern and practice to use the
channels and instrumentalities of interstate and foreign commerce (private jets, yachts,
and commercial airplanes) to entice, recruit, solicit, harbor, provide, obtain, and
transport young women, and young men for purposes of causing commercial sex acts,
in violation of 18 U.S.C. § 1591(a)(1).
t. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group and its employees had
actual knowledge that they were facilitating Combs' sexual abuse and sex trafficking
conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain and propel Mr.
Jones into commercial sex acts, through the means of force, threats of force, fraud,
abuse of process, and coercion, and a combination of all these means.
u. Upon information and belief, despite such knowledge, Defendants Lucian Charles
Group intentionally paid for, facilitated, and participated in Combs' violations of 18
U.S.C. § 1591(a)(1), which Defendants Lucian Charles Grainge in his capacity as
CEO of UMG, Motown Records, and Universal Music Group knew, and were in
reckless disregard of the fact that Combs would coerce, defraud, and force Mr. Jones
to engage in commercial sex acts.
v. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, through its employees
and agents, actively participated in the sex trafficking conspiracy and led Mr. Jones
and sex workers to believe that they would be rewarded if they cooperated and
acquiesced to Mr. Combs' coercive demands.
w. Upon information and belief, Defendants Lucian Charles Grainge in his capacity as
CEO of UMG, Motown Records, and Universal Music Group's affirmative conduct
was committed knowingly, and in reckless disregard of the facts, that Mr. Combs
would use the financial support provided by Defendants Lucian Charles Grainge in
his capacity as CEO of UMG, Motown Records, and Universal Music Group as a
means of defrauding, forcing, and coercing sex acts from Mr. Jones. Defendants
Lucian Charles Grainge's capacity as CEO of UMG, Motown Records, and Universal
Music Group's conduct was outrageous and intentional.
x. Upon information and belief, in addition to actual knowledge that it was participating
in and facilitating the Combs sex-trafficking venture, Defendants Lucian Charles
Group, also should have known that it was participating in and facilitating a venture
that had engaged in coercive sex trafficking, as covered by 18 U.S.C. § 1595(a).
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y. Upon information and belief, in exchange for facilitating and covering up Combs'
commercial sex trafficking, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, received international
recognition, notoriety, and praise for the establishment of Love Records, Inc., and the
development and distribution of the Love Album. This was a result of securing the
Sean Combs Love Records, Inc. relationship.
z. Facilitating and covering up Combs' sexual trafficking and misconduct was a means
of obtaining economic success and promotion within the Defendants Lucian Charles
Grainge in his capacity as CEO of UMG, Motown Records, and Universal Music
Group hierarchy.
aa. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, knowing and
intentionally conduct, has caused Mr. Jones serious harm, including, without
limitation, physical, psychological, emotional, financial, and reputational harm.
bb. Upon information and belief, Defendants Lucian Charles Grainge, in his capacity as
CEO of UMG, Motown Records, and Universal Music Group, knowing and
intentionally conduct has caused Mr. Jones harm that is sufficiently serious, under all
the surrounding circumstances, to compel a reasonable person of the same background
and in the same circumstances to perform or to continue performing a commercial
sexual activity, to avoid incurring that harm.
cc. This case does not involve mere fraud. Instead, Defendants Lucian Charles Grainge,
in his capacity as CEO of UMG, Motown Records, and Universal Music Group, 's
criminal conduct in violating the TVPA was outrageous and intentional because it was
in deliberate furtherance of a widespread and dangerous criminal sex trafficking
organization. Defendants Lucian Charles Grainge, in his capacity as CEO of UMG,
Motown Records, and Universal Music Groups' willful blindness to Combs' criminal
conduct also evinced a high degree of moral turpitude and demonstrated such wanton
dishonesty as to imply a criminal indifference to civil obligations. Defendants Lucian
Music Group's criminal conduct was directed specifically at Mr. Jones, who was the
victim of Combs' sexual abuse and sex trafficking organization.
dd. Upon information and belief, Defendants Lucian Charles Grainge in his capacity as
CEO of UMG, Motown Records, and Universal Music Group's outrageous and
intentional conduct, in this case, is part of a pattern and practice of Defendants Lucian
Music Group profiting by undertaking illegal "high risk, high reward" general business
partnerships.
Universal Music Group, is liable to Mr. Jones for the damages he sustained and reasonable
attorneys' fees.
///
///
///
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SIXTEENTH CAUSE OF ACTION

OBSTRUCTION OF THE ENFORCEMENT OF THE TRAFFICKING VICTIM
PROTECTION ACT, 18 U.S.C. § 1591(d)
(against, Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown
Records, and Universal Music Group)
forth fully herein.
and Universal Music Group and its officers and employees knowingly and intentionally
obstructed, attempted to obstruct, interfered with, and prevented the enforcement of 18 U.S.C.
§§ 1591(a)(1) & (a)(2), all in violation of 18 U.S.C. § 1591(d). This activity is hereinafter
referred to collectively simply as “obstruction.”
of UMG, Motown Records, and Universal Music Group’s obstruction of the enforcement of
18 U.S.C. §§ 1591(a)(1) and (a)(2) was forbidden by 18 U.S.C. § 1591(d), and Defendants
Lucian Charles Grainge in his capacity as CEO of UMG, Motown Records, and Universal
Music Group thereby violated Chapter 77, Title 18. Defendants Lucian Charles Grainge in his
capacity as CEO of UMG, Motown Records, and Universal Music Group’s obstruction
described here and in the preceding paragraph directly, proximately, and foreseeably harmed
Mr. Jones by directly resulting in him coercively being caused to engage in commercial sex
acts and in other ways.
380. Upon information and belief, Defendant Sean Combs has a well-documented history of
criminal investigations. Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Group were on notice of Mr. Combs proclivity to
criminal activity. They knew or should have known that Mr. Combs sex-trafficking operation
would or could result in a criminal investigation by State and Federal prosecutors for violating
(among other laws) the TVPA. Defendants Lucian Charles Grainge in his capacity as CEO
of UMG, Motown Records, and Universal Music Group should have taken a que from the
Federal Prosecutors arrest and prosecution of Jeffrey Epstein on or about July 8, 2019. On or
about that date, the U.S. Attorney’s Office for the Southern District of New York indicted
Epstein (and unnamed “associates”) for violating the TVPA. Later, on about June 29, 2020,
the same Office indicted Epstein’s co-conspirator, Ghislaine Maxwell, for conspiracy to entice
minor victims to travel to be abused by Epstein. Mr. Combs, Defendants J. Combs, Khorram
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and her direct reports: Brendan Paul, Frankie Santella, and Moy Baun all engaged in the same
activities as Mr. Epstein and Ms. Maxwell. In fact, Mr. Combs, Defendants J. Combs,
Khorram and her direct reports: Brendan Paul, Frankie Santella, and Moy Baun may have
done worse.
381. Upon information and belief, by providing financing for Mr. Combs’ sex trafficking
organization, and concealing its actions thereafter, Defendants Lucian Charles Grainge in his
capacity as CEO of UMG, Motown Records, and Universal Music Group obstructed,
interfered with, and prevented the state and federal government enforcement of the TVPA
against Mr. Combs, Defendants J. Combs, Khorram and her direct reports: Brendan Paul,
Frankie Santella, and Moy Baun. To the extent that the federal government was able to
ultimately charge Mr. Combs, Defendants J. Combs, Khorram and her direct reports: Brendan
Paul, Frankie Santella, and Moy Baun with TVPA violations, the filing of those charges was
delayed by Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown
Records, and Universal Music Group’s actions. Because of that delay, Mr. Jones was
coercively caused to engage in commercial sex acts.
382. As one example of how Defendants Lucian Charles Grainge in his capacity as CEO of
UMG, Motown Records, and Universal Music Group obstructed, attempted to obstruct,
interfered with, and prevented state and federal government’s enforcement of the TVPA,
Defendants Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown
Records, and Universal Music Group provided financial resources to Mr. Combs and so that
the coercive commercial sex acts would escape the detection of state and federal law
enforcement and prosecuting agencies. Defendants Lucian Charles Grainge in his capacity as
CEO of UMG, Motown Records, and Universal Music Group provided financial resources to
further the Mr. Combs, Defendants J. Combs, Khorram and her direct reports: Brendan Paul,
Frankie Santella, and Moy Baun sex-trafficking venture and with the purpose of helping Mr.
Combs, Defendants J. Combs, Khorram and her direct reports: Brendan Paul, Frankie
Santella, and Moy Baun evade criminal liability for violating the TVPA.
383. As an example of how Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Group obstructed, attempted to obstruct, interfered
with, and prevented state and federal government’s enforcement of the TVPA, Defendants
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Music Group failed to ensure that their general business partners, Sean Combs and Love
Records, Inc. timely and accurately reported to the federal government the required tax forms
that detailed the partnership payments provided by Defendants Lucian Charles Grainge in his
capacity as CEO of UMG, Motown Records, and Universal Music Group to Mr. Combs.
Timely filing of these reports is required by the United States Tax code and related laws and
regulations. These reports are tools that the federal government uses to detect and prosecute,
among other illegal activities, sex trafficking in violation of the TVPA. By failing to ensure
that their general business partner timely and accurately filed, the required tax reporting
documents regarding Mr. Combs’ partnership financial transactions, Defendants Lucian
Group obstructed, attempted to obstruct, interfered with, and prevented the government’s
enforcement of the TVPA by concealing from the government’s attention Mr. Combs’
financing in aid of sex trafficking.
384. By providing unchecked financial support to Mr. Combs, Defendants Lucian Charles
Grainge in his capacity as CEO of UMG, Motown Records, and Universal Music Group
intended and knew that Mr. Combs’ coercive commercial sex acts would escape the detection
of law enforcement and prosecuting agencies for some period of time. Defendants Lucian
Group provided financial support to further the Combs sex-trafficking venture and with the
purpose of helping Mr. Combs evade criminal liability for violating the TVPA.
of UMG, Motown Records, and Universal Music Group’s obstruction, attempted obstruction,
interference with, and prevention of the enforcement of the TVPA were all done intentionally
and knowingly. For example, Defendants Lucian Charles Grainge in his capacity as CEO of
UMG, Motown Records, and Universal Music Group knew that Mr. Combs was high risk—
specifically, high risk to violate the TVPA through continuing criminal sex trafficking
activities. As evidenced by Cassie Ventura’s civil complaint, she informed members of Mr.
Combs parent label about the abuses he was visiting upon her, and instead of coming to her
rescue, they forced her to return his calls and to return to his sex trafficking enterprise.
of UMG, Motown Records, and Universal Music Group was aware Mr. Combs had a laundry
92
list of criminal charges, and barely escaped serving prison time. Upon information and belief
Mr. Combs engaged in witness intimidation, and bribery to escape criminal liability for
shooting Natania Reuben in the face. Defendants Lucian Charles Grainge in his capacity as
CEO of UMG, Motown Records, and Universal Music Group was aware that there were
public allegations that Mr. Combs illegal conduct was facilitated by several named co-
conspirators. They were made aware of this through complaints made my Cassie Ventura,
and the lawsuit by former Diddy sex worker Jonathan Oddi. Defendants Lucian Charles
Grainge in his capacity as CEO of UMG, Motown Records, and Universal Music Group
concealed from federal the government its numerous financial payments to Mr. Combs and
Love Records, Inc. Defendants Lucian Charles Grainge in his capacity as CEO of UMG,
Motown Records, and Universal Music Group continued its affirmative conduct of providing
financing to Mr. Combs so that he could make payments to his co-conspirators with
knowledge that such transactions did not produce a clear paper trail. Defendants Lucian
Group’s intentional conduct obstructed, attempted to obstruct, in many ways interfered with,
and prevented the enforcement of the TVPA by investigators and prosecuting agencies.
of UMG, Motown Records, and Universal Music Group’s relationship with Mr. Combs in
providing to his sex- trafficking venture with unchecked financing went far beyond a normal
(and lawful) partnership relationship. Defendants Lucian Charles Grainge in his capacity as
CEO of UMG, Motown Records, and Universal Music Group knew, and intended, that its
relationship with Mr. Combs would go far beyond a normal music industry relationship.
Universal Music Group knew that its decision to go beyond a normal music relationship with
Mr. Combs obstructed the ability of law enforcement and prosecuting agencies to enforce the
TVPA.
of UMG, Motown Records, and Universal Music Group’s obstruction of the government’s
TVPA and other law enforcement efforts was intentional and willful and, therefore,
Universal Music Group intentionally and willfully caused Mr. Combs’ commission of the
93
forcible commercial sex acts with Mr. Jones through its obstruction supporting the
concealment of Mr. Combs’ sex-trafficking venture. Defendants Lucian Charles Grainge in
his capacity as CEO of UMG, Motown Records, and Universal Music Group knew that Mr.
Combs and his other co-conspirators would use means of force, threats of force fraud,
coercion, and a combination of such means to cause Mr. Jones to engage in commercial sex
acts.
of UMG, Motown Records, and Universal Music Group knew, acted in reckless disregard of
the fact, and should have known, that its obstruction in violation of 18 U.S.C. § 1591(d) would
directly and proximately lead to unlawful coercive commercial sex acts by Mr. Combs with
men, like Plaintiff Jones, young men, and young women.
of UMG, Motown Records, and Universal Music Group’s obstruction has caused Mr. Jones
serious harm, including, without limitation, physical, psychological, financial, and
reputational harm. That harm was directly and proximately caused by the obstruction and the
harm resulting from obstruction was foreseeable.
of UMG, Motown Records, and Universal Music Group’s obstruction has caused Mr. Jones
harm that is sufficiently serious, under all the surrounding circumstances, to compel a
reasonable person of the same background and in the same circumstances to perform or to
continue performing commercial sexual activity to avoid incurring that harm.
392. Upon information and belief, this case does not involve mere fraud. Instead, Defendants
Music Group’s criminal conduct in obstructing enforcement of the TVPA was outrageous and
intentional because it was in deliberate furtherance of a widespread and dangerous criminal
sex trafficking organization. Defendants Lucian Charles Grainge in his capacity as CEO of
UMG, Motown Records, and Universal Music Group’s obstruction also evinced a high degree
of moral turpitude and demonstrated such wanton dishonesty as to imply a criminal
indifference to civil obligations. Defendants Lucian Charles Grainge in his capacity as CEO
of UMG, Motown Records, and Universal Music Group’s obstruction was directed
specifically at Mr. Jones who was the victim of Mr. Combs’ sex trafficking organization.
94
393. By virtue of these violations of 18 U.S.C. § 1591(d), Defendants Lucian Charles Grainge
in his capacity as CEO of UMG, Motown Records, and Universal Music Group is liable to
Mr. Jones for the damages he sustained and reasonable attorneys’ fees by operation of 18
U.S.C. § 1595. Defendants Lucian Charles Grainge in his capacity as CEO of UMG, Motown
Records, and Universal Music Group perpetrated an obstruction of the TVPA, and therefore
perpetrated a violation of Chapter 77, Title 18.
SEVENTEENTH CAUSE OF ACTION

Breach of Oral Contract
(against, Love Records, and Sean Combs)
forth fully herein.
395. Plaintiff Jones and Defendants Mr. Combs and LR had an oral contract for Mr. Jones to
receive $20,000 for every song he produced on the Love Album. Mr. Combs agreed to allow
Mr. Jones to keep his publishing, as well as 4 royalty points per song, and to credit him as a
producer for every song that he touched, as well as credit him for each instrument he played.
396. Mr. Jones fully executed his obligations under the contract when he produced: Deliver Me,
Stay PT 1, Reachin’, What’s Love, Stay Awhile, Moments, Need Somebody, Homecoming, and
Tough Love.
397. Mr. Jones worked on the following songs: Brought My Love, and Creepin Remix.
398. Mr. Jones lived and traveled with Mr. Combs from September 2022 to October 2023.
Through the duration of that time Mr. Combs did not compensate Mr. Jones for his time or
the work he did on the above-mentioned songs. Mr. Combs also failed to provide Mr. Jones
with producer credit, or 4 royalty points for all songs.
399. As a result of Mr. Combs’ actions, Mr. Jones has suffered the following losses: $180,000,
4 royalty points, and producer credit for the following songs: Deliver Me, Stay PT 1, Reachin’,
What’s Love, Stay Awhile, Moments, Need Somebody, Homecoming, and Tough Love.
400. As a result of Mr. Combs’ actions, Mr. Jones has suffered the following losses: $40,000, 4
royalty points, and producer credit for the following songs: Brought My Love, and Creepin
Remix.
95
401. As a result of Mr. Combs’ breach of contract, Mr. Jones has suffered and continues to
suffer harm, including severe emotional distress, anxiety, and other consequential damages
for which he is entitled to an award of monetary damages and other relief.
402. The conduct of Mr. Combs described above was willful, wanton, and malicious. At all
relevant times, Mr. Combs acted with conscious disregard for Plaintiff's rights and feelings,
acted with the knowledge of or with reckless disregard for the fact that his conduct was certain
to cause injury to Plaintiff Jones. By virtue of the foregoing, Plaintiff is entitled to recover
punitive damages.
PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against Defendants,
containing the following relief:
a. A declaratory judgment that the actions, conduct, and practices of Defendants
complained of herein violate the laws of the State of New York;
b. An award of damages against Defendant, in an amount to be determined at Trial,
plus prejudgment interest, to compensate Plaintiff for all monetary and/or economic
damages, including, but not limited to, loss of past and future income, wages,
compensation, seniority, and other benefits of employment;
c. An award of damages against Defendant, in an amount to be determined at Trial,
plus prejudgment interest, to compensate Plaintiff for all non-monetary and/or
compensatory damages, including, but not limited to, compensation for her mental
anguish, humiliation, embarrassment, stress and anxiety, emotional pain and
suffering, and emotional distress;
d. An award of punitive damages, in an amount to be determined at Trial;
e. Prejudgment interest on all amounts due;
f. An award of costs that Plaintiff has incurred in this action, including, but not limited
to, expert witness fees, as well as Plaintiff’s reasonable attorneys’ fees and costs to
the fullest extent permitted by law; and,
g. Such other and further relief as the Court may deem just and proper.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all issues of fact and damages stated herein.
Dated: March 25, 2024

Brooklyn, New York
T. A. BLACKBURN LAW, PLLC.
By:
Tyrone A. Blackburn, Esq.
Attorney for Plaintiff
1242 E. 80th Street, 3rd Floor
Brooklyn, New York 11236
96
PRESERVATION NOTICE
The term "you," "your," or "yours" as used herein shall refer to you (the recipient of this letter), as
well as to the respondents and any individuals responsible for the custody and control of the below
information, including, but not limited to, those individuals' administrative assistants, secretaries,
agents, employees, information technology personnel and third-party vendors. From this point
forward, you are directed to prevent "spoliation," defined as altering, changing, updating,
destroying (even if periodically), editing, or deleting any information set forth hereafter.
If you cause any such alteration, destruction, or change, direct it, or allow it to occur, you may be
charged with discovery rule violations for which sanctions may be imposed. Further, your failure
to abide by this request could result in severe penalties against you and form the basis of legal
claims for spoliation.
Electronically Stored Information:

In terms of electronically stored information, you are directed to prevent any destructive,
alternative or other change to any web pages, virtual profiles or identical (including, but not limited
to, Facebook, Instagram, Pinterest, Twitter, Tumblr, LinkedIn, Snapchat, Google Plus+, Flickr,
Vine, About.me, ask.fm etc., or any other social media-based web profile or networking site
account), emails, voice messages, text messages, instant messages or messaging systems,
recordings, digital recordings, media images and videos, temporary memory, memory sticks,
portable memory devices, laptops or computers, CDs, DVDs, USB devices, databases, computer
activity logs, internet browsing history (including cookies), network access and server activity
logs, word processing files and file fragments, backup and archival files, imaging and facsimile
files, electronic calendar and scheduling program files and file fragments as well as any other
contact and relationship management data (e.g., Outlook), electronic spreadsheet files and file
fragments, pertaining in any way to this controversy of the parties or any potential witnesses. This
includes a request that such information not be modified, altered, or deleted due to data
compression or disk fragmentation (or other optimization procedures), which processes you are
hereby directed to suspend until that data can be preserved, copied, and produced.
You are directed not to modify, alter, or delete or allow modifications, alterations, or deletions to
be made to any electronically stored information. You are further directed to preserve all, and not
to destroy any, passwords, decryption productions (including, if necessary, the software to decrypt
the files), network access codes, manuals, tutorials, written instructions, decompression or
reconstruction software, and any other information and things necessary to access, view and (if
necessary) reconstruct the electronic data we will request through discovery.
Paper Information:
Regarding the paper information, you are directed to preserve any emails, videos, texts, memos,
reports, documents, notes, correspondence, photographs, investigative information, or other
documents about the controversy, parties, or witnesses. We expect to obtain several documents
and other data from you through discovery, including text messages, emails, photographs, and
other information stored on computers, electronic devices, and telephones.
Although we may bring a motion with a court for order-preserving documents and other data from
destruction or alteration, your obligation to preserve documents and other data for discovery, in
97
this case, arises independently from any order on such motion. Electronic documents and the
storage media, including but not limited to telephones on which they reside, contain relevant,
discoverable information beyond what may be found in printed documents. Therefore, even where
a paper copy exists, we will likely seek all documents in their original, electronic form, along with
metadata or information about those documents on the media. We will seek paper printouts of
only those documents that contain unique information created after they were printed (e.g., paper
documents containing handwriting, signatures, marginalia, drawings, annotations, highlighting,
and redactions) and any paper documents for which no corresponding electronic files exist.
The laws and rules prohibiting the destruction of evidence apply to electronically stored
information in the same manner they apply to other evidence. Due to its format, electronic
information is quickly deleted, modified, or corrupted. Accordingly, the demand is made that you
take every reasonable step to preserve this information until the final resolution of this matter.
This may include, but would not be limited to, an obligation to discontinue all data destruction and
backup tape recycling policies.
Concerning electronic data created after this Complaint's delivery date, relevant evidence should
not be destroyed. You must take the steps necessary to avoid the destruction of such evidence.

Brooklyn, New York
By:
DEMAND FOR INSURANCE COVERAGE

Defendants are demanded to provide a complete copy of their applicable insurance policies and
declaration sheets demonstrating coverage within thirty (30) days of service of this Complaint.

Brooklyn, New York
By:
98

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Case 1:24-cv-01457-JPO Document 27 Filed 03/27/24 Page 1 of 98

UNITED STATES FEDERAL COURT

Plaintiff, Case Number: 24-1457

V. Second Amended Complaint

JURISDICTION AND VENUE

Defendant Sean Combs

Defendant Justin Dior Combs

Lucian Charles Grainge

Cuba Gooding, Jr.

Kristina Khorram, Chief of Staff to Sean "Diddy" Combs

b. The displaying and distribution of unregistered illegal firearms,

CHALICE RECORDING STUDIOS SHOOTING

Aftermath of the Shooting of G

CHALICE RECORDING STUDIOS, AND DEFENDANTS SEAN COMBS AND JUSTIN

Mr. Combs Published the Love Records Chalice Recording Studios

THE DEAFENING SILENCE FROM THE ATTENDEES OF THE CRS SHOOTING

MR. JONES WAS SEXUALLY HARASSED, AND ASSAULTED BY MR. COMBS

THANKSGIVING 2022, MR. JONES IS SEXUALLY ASSAULTED BY

TRAFFICKING AND VICTIMS’ PROTECTION ACT

Booby Trap on the River

MR. JONES HAS PERSONALLY WITNESSED MR. COMBS AND J. COMBS

THE LOVE ALBUM

DeForrest Taylor Threatening Mr. Jones

DEFENDANT LUCIAN CHARLES GRAINGE IN HIS CAPACITY AS CEO OF UMG,

DEFENDANT KRISTINA KHORRAM IS THE GHISLAINE MAXWELL

Brendan Paul and Mr. Combs

d. Frankie Santella25: Works alongside Brendan. While Brendan acquires, and

Frankie Santella and Sean Combs

MR. COMBS IS ALLOWED TO WREAK HAVOC

FIRST CAUSE OF ACTION

Mr. Jones and Brendan wearing the Bad Boy Hat

benefited, financially or by receiving anything of value, in a venture which has engaged in an

Kristina Khorram's consent. Defendant Combs property is protected by 24-hour

Sex Worker 2 (87) 2/8/23, 2/9/23, 4/4/23 2 Star Island Drive in

Sex Worker 3 (82) 11/29/22, 1/26/23, 2 Star Island Drive in

Sex Worker 4 (82) 11/30/22, 12/1/22, 2 Star Island Drive in

Sex Worker 5 (77) 2/1/23, 2/2/23, 2/4/23, 2 Star Island Drive in

Sex Worker 6 (43) 1/28/23, 1/28/23 2 Star Island Drive in

Sex Worker 7 (31) 12/3/22, 12/6/22, 2 Star Island Drive in

Sex Worker 8 (72) 5/8/23 2 Star Island Drive in

Defendants Committed Multiple Acts of procuring, transporting, and distributing controlled

DeForrest Taylor 11/22/2022 Los Angeles, California to

Brendan Paul 12/22/2022 Miami, Florida to Saint

Brendan Paul38, and 04/28/2023 Los Angeles – to New

Defendants Committed Multiple Acts of Wire Fraud in Violation of 18 U.S.C. § 1343 in

SECOND CAUSE OF ACTION

FOURTH CAUSE OF ACTION

FIFTH CAUSE OF ACTION

SIXTH CAUSE OF ACTION

SEVENTH CAUSE OF ACTION

EIGHT CAUSE OF ACTION

NINTH CAUSE OF ACTION

ELEVENTH CAUSE OF ACTION

FOURTEENTH CAUSE OF ACTION

FIFTEENTH CAUSE OF ACTION

SIXTEENTH CAUSE OF ACTION

SEVENTEENTH CAUSE OF ACTION

PRAYER FOR RELIEF

Dated: March 25, 2024